ML19254E127
| ML19254E127 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/16/1979 |
| From: | Churchill B, Oneill J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TOLEDO EDISON CO. |
| To: | |
| Shared Package | |
| ML19254E120 | List: |
| References | |
| NUDOCS 7910310125 | |
| Download: ML19254E127 (25) | |
Text
July 16, 1979
~
UNITED STATES OF AMERICA NULLEAR REGULATORY COMMISSION OFFICE OF NUCI EAR REACTOR REGULATION TOLEDO EDISON COMPANY AND
)
THE CLEVELAND ELECTRIC
)
Docke t No. 50-346 ILLUMINATING COMPANY
)
)
DAVIS-BESSE NUCLEAR POWER
)
Request under STATION, UNIT NO. 1
)
10 C.F.R. 5 2.206 LICENSEES' RESPONSE TO TOLEDO COALITION FOR SAFE ENERGY'S RECUEST CNDER 10 C.F.R. S 2.206 By letter to Mr. James G.
Keppler, Director, Reg ion III, Of fice of Inspection and Enfo rcement, dated April 24, 1979 (as c' u:ified in a letter to Mr. Stephen Burns, OELD, dated May 23, _979, and in a le tter to Mr. Harold Denton, Director, Office of Nuclear Reactor Regulation, dated June 12, 1979), and by letter to Mr. Harold Denton dated July 9, 1979 (enclosing a
" Motion for Preliminary Injunction"
(" Motion") and a " Complaint and Memorandum of Particulars"
(" Complaint")), Toledo Coalition for Safe Energy ("TCSE") requests the Director to institute a proceeding to cause certain modifications to the emergency plan for Davis-Besse Nuclear Power Station, Unit 1.
Further, in the Motion, TCSE moves "for a preliminary injunction or suspension of power generating operations at Davis-Eesse Nuclear Power I243 004
,p,
Station, Unit No. 1, with an inj unc tion to Toledo Edison Company (TECo) and the Cleveland Electric Illuminating Company (GEI)
(" Licensees"]...
pending a final determination of the need for and implementation of definitive corrective measures to be taken upon the operating license issued to said respon-dents, from restarting Davis-Besse I..."
Licensees hereby respond to TCSE's request.
As will be demcnstrated below, TCSE is misinformed, has alleged factually inaccurate statements, and har, not demonstrated tha t Licensees are in violation of any NRC regulations ot that a potentially hazardous condition, exists suf ficient to institute a "show cause" proceeding under 10 C.F.R. S 2.202.
- Further, TCSE has no right to move for a preliminary
'iunction, and even if it did, TCSE has not, and could not, maxe a showing of irreparable injury or likelihood of cuccess on the merits which would justify even considering the extraordinary legal remedy of injunction.
I.
THE CCCUMENT WITH WHICH TCSE FINDS FAULT IS NOT LICENSEES' EMERGENCY PLAN The gravamen of TCSE's Complaint and the basis for its request under S 2.206 is the alleg ation tha t Licensees "have failed to formulate a comprehensive, workable and dependable emergency and evacuation plan, and have thus ignored fede ral-requirements. "
(Complaint at 3).
TCSE apparen tly r
37A 005.
believes Licenseet ' presently effective emergency plan is the document entitlei Savis-Besse Nuclear Power Station Emergency Plan" found at. Appendix 13-D of the " Final Safety Analysis Report of the Davis-Besse Nu lear Power Station" ("FSAR").
In fact, the effective emergency plan, which is incorporat<; in to the operating license for Davis-Besse Nuclear Power Station Unit No. 1, is an Administrative Document entitled " Davis-Besse Nuclear Power Station Unit No.
1, Auministrative Procedure AD 1827.00, Emergency Plan" (the " Emergency Plan"), which was originally issued on November 12, 1975.
The Emergency Plan is suppor ted by twenty-four Emerge,ncy Plan Implementing Procedures, all bound in a volume over two inches thick.
No mention is made by TCSE of this document.
The Emergency Plan and the Emergency Plan Implementing Procedures provide spe-cific, detailed guidance for actions and responsibi'ities of plant personnel in the event of an emergency, as compared to the more general guidance found in the FSAR Emergency Plan.
Thus the document with which TCSE seeks to find fault is not Licensees' Emergency Plan.
II.
LICENSEES' IMERGENCY PLAN MEETS ALL /PPLICABLE NRC REQUIREMENTS Licensees' Emergency Plan meets all NRC requirements.
The Emergency Plan has been inspec ted ag ain s t all applicable NRC requirements annually since 1975 by Region III, Office of f.
. 1243 006
Inspection and Enforcement ("I&E").
The most recent inspec-tion, completed on June 15, 1979, resul ted in one deviation from requirements -- the documentation of the station review of the Emergency Plan was entered three days late.
As required by 10 C.F.R. Part 50, Appendix E, an annual drill to test the Emergency Plan's effectiventss has been held since 1975.
The last such drill, conducted in 1978, 5 as observed by Mr. Al Januska from Region III, I&E.
In addition to having reviewed the wrong emergency plan, TCSE used the wrong documents in attempting to detsemine if the emergency plan met NRC requirements.
For example, TCSE faults the FSAR Emergency Plan for not complying with the recommendations of the NRC and EPA's Task Force on Emergency Planning in ' Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants", NUREG-0396/ EPA 520/1-78-016 (December, 1978)
(" Planning Basis").
The purpose of the Planning Basis "is to provide a basis for Federal, State and local government emergency preparedness organizations to de te rmine the appropriate degree of emergency response planning effotts in the environs of nuclear power plants."
(Planning Basis at i).
The Planning Basis does not address directly licensee emergency plans and, in any event, is only a report which makes recommendations to the Commission; its recommenda-tions are not requirements of the NRC or any other federal gency.
TCSE has misapplied this documen t.
1243 OCfl.
In Appendix A (attached hereto) we address TCSE's specific allegations in the Complaint of Licensees' failure to meet NRC requir,ements.
III. THE COMMISSION HAS INITIATED PROPOSED RULEMAKING TO DEAL WITH THE ADEQUACY AND ACCEPTANCE OF EMERGENCY PLANNING AROUND NUCLEAR FACILITIES ON A GENERIC BASIS; INSTITUTING A SHOW CAUSE PROCEEDING CONCERNING LICENSEES' EMERGENCY PLAN WHICH MEETS PRESENT COMMISSION REQUIREMENTS WOULD BE AN INAPPROPRIATE AND INEFFICIENT METHOD OF DEALING WITH THE GENERIC ISSUES TCSE's request raises a number of generic issues that are presently under consideration by the Commission as part of a comprehensive review of feder51, state, local and licensee emergency planning and coordination.
As a result of the lessons learned during the Three Mile Island acc id en t, e.mer-gency planning is undergoing intensive review within the Commission and throughout the country by federal, state and local governmental unit..
As indicated in the next section, this has been especially true for Licensees and the State of Ohio who have been actively evaluating their present emergency planning assumptions and procedures.
Even before Three Mile Island, emergency planning was undergoing Commission review as ind ica ted in the 1RC/ EPA Task Force Report, Planning Basis.
The Commission has currently pending a proposed rule which would require licensees to address emergency planning con-siderations to areas outside the low population zone.
43 Fed.
+
Reg. 37473 (August 23, 1978).
}2kb.
Furthermore, a number of organizations, includ ing Critical Mass and Public Interest Research Groups, have joined in a petition for rulemating co cerning the operational details of evacuation planni'.g.
See 44 Fed. Reg. 32486 (June 6, 1979).
TCSE specifically agreed to treat the " demands" set forth in its April 24, 197 9 le t te r to Mr. Keppler as a petition for rulemaking to be consolidated with the Critical Mass petition.
See TCSE letter to Mr Harold Denton dated June 12, 1979.
The issues raised by TCSE with respect to emergency planning are more appropriately addressed in a rulemaking proceeding.
On June 7, 1979, the Commission established a Task Force on Emergency Planning, which was given the following charter for its initial phase of activities:
Task 1 - Develcp for Commission con ideration a list of major issues, vita ten ta tive alternative solutions, that should be addressed through rulemaking proceedings.
Task 2 - Concurrently with Task 1, describe and objectively critique NPC's current emergency planning precess, especially considering recent TMI lessons learned.
Task 3 - Define and recommend an approach for developing a comprehensive plan that would formulate the scope, direc2 ion, and pace for NRC's overall emergency planning activities.
Task 4 - Brief Lne Commission on results of Tasks 1-3, issues requiring Commission guidance, and future plans.
The second phase assignment of the Task Force is to develop a v
comprehensive plan for the Commiss' ion to deal with emergency 1243 009.
planning issues by early August, 1979.
(See memorandum to all NRC Of fice Directors from Lee Gossick dated June 11, 1979.)
The Task Force briefed the Commission on June 28, 1979, identifying the major issues to be addressed.
The Task Force noted that aouitionally I&E and the NRR Task Force on
" lessons learned" from Three Mile Island were both delving in to
~
the emergency planning issues.
Some of the issues raised by TCSE (such as the 10 mile Emergency Planning Zone for stats emergency plans) were discussed by the Task Force as issues to be considered.
(See Transcript of NRC Commissioners' Public Meeting, Sriefing on Emergency planning Task Fo rce, Washing ton,
D.C.,
(June 28, 19791).
On July 12, 1979, the Commission published an Advance Notice of Proposed Rulemaking (attached hereto as Appendix 3) soliciting public comment on " objectives for effective plans, acceptance criteria for State / local emergency plans, NRC concurrence in State and local plans as a requirement for issuance of an operating license or for continued operation of a nuclear facility, and coordination betwcen licensee plan and State and local plans."
The public, including TCSE if it so desires, will have 45 days af ter publication in the Federal Reg is te r to comment on the proposed rulemak ir:g.
Moreover, as mentioned above, TCSE is already par ticipating in the proposed rulemaking initiated by the Critical Mass petition.
It is clear that the Commission is ac.tively considering the issues raised by TCSE and many other eme'rgency 1243 010.
planning issues on a generic basis.
Because the Licensees presently mee t NRC requirements, it would be inappropriate and idefficient for. the Director to deal with these same issues in a show cause proceeding.1 IV.
LICENSEES AND THE STATE OF OHIO HAVE INITIATED THEIR OWN REVIEWS OF EMERGENCY PLANNING The Licensees have been actively engaged in a continuing program for upgradiny, updating, and impr oving the Emergency Plan.
Immediately af ter the Three Mile Island acciden t in March, this program;was intensified and formalized with the formation of an Emergency Plan Task Force under the direction of the Davis-Besse Nuclear Power Station Administrative Coordinator.
Plant employees assigned to the Task Force have already expended considerable effort in discharging their assigned responsibilities to ensure tha t current regulatory requirements are sa tis fied, to continually review and te s t the Emergency Plan to ensure that it is practical and workable, to ensure tha t the lines of communica-tion between company and outside officials are kept open and 1
Nowhere in the Advance Notice of Proposed Rulemaking, or in the transcripts of the Commissioners' meetings estab-lishing or being briefed by the Task Force on Emergency Plan-ning, or in the NRC/ EPA Planning Basis, has the suggestion be made that the public health and safety requires immediate revisions to emergsncy plans.
+
} } k f O '\\ \\.
current, to work with local and State government officials to ensure coordination of emergency preparedness, and to ensure that adequate reporting and information dissemination will be available.
In reviewing and upgrading the Emergency Plan, the Licensees have gone well beyond current NRC regulatory require-ments.
The Task Force, for example, is currently in the process of modifyin'- the p1 n to meet the latest NRC recommen-dations i.n Regulatory Guide 1.101, guidance which is not a requirement under the Davis-Besse license.
In add ition, a corporate level task force, under the direction of the Vice-President for Administrative Services, y
was formed to develop comprehensive emergency plans which encompass not only plans for the station but additionally such areas as the adequacy of security, communication, public pro tec tio n, support facilities, and liaison with the press and governmental bodics.
While the Davis-Besse Emergency Plan, includ ing the response of its outside supporting agencies, has been tested annually, The Toledo Edison Company is assuming a role of leadership in planning a much more comprehensive t2st of emergency planning this year which will coordinate the efforts for all levels of emergency planning in the S ta te of Ohio.
Planning effort _ have already been initiated with the partici-pation of the Ohio State Nuclear Prepared :ess Officer, the Nrr and the Davis-Besse Nuclear Power Sta tion.
A briefing for
~
agencies representing Ottawa County has been scheduled in the
\\ } 0r b
_9_
near future.
A series of coordinating meetings will be carried out to effect an annua.' drill which will exercise on a coor-dinated basis the Ohio State, Ottawa County and Davic-Besse station emergency plans.
As part of the Davis-Besse emergency preparednes program, the Licensees have had continuing contact with
~
representatives of the public to provide information regarding emergency planning.
rhese efforts have included meetings with State, Ottawa County and Carroll rownship officials and governing bodies, as well as testimony before the Committee on Energy and Environment of the Ohio State Hous ' of Representatives.
Toledo Edison officials have also been involved in the extensive activities by the State of Ohio in the review and modification of the Ohio State Emergency Plan.
The State has had an emergency plan in ef fect since before Davis-Besse became operational, and has recently made comprehensive changes to the plan for the purpose of conforming with all 70 elements of the ~
NRC's primary emergency planning guidance.
The revised Ohio State Emergency Plan, which was submitted to the NRC in June, includes evacuation and emergency planning for Ottawa Coun ty and Carroll Township, and encompasses at least the area within a ten-mile radius of the plant.
In add ition, the Governor of Ohio has appointed a Task Force on Nuclear Plant Safety to review safety programs at
~
the three nuclear power plants in Ohio, with specific attention 24 013.
directed toward existing emergency plans and the procedures for coordinating the plans with local officials.
The investiga-tions are cagoi'ng, but 'the Task Force reported to the Governor
~
in April of this year its initial findir.gs that the plans in effect meet the standards of the Federal government and are rensidered adequate for the health and safety of Ohio citizens.
V.
AS A MATTER CF LAW TCSE IS NOT ENTITLED TO THE EMERGENCY RELIEr REQUESTED IN THE MOTION There can be no question that TCSE's series of submissions, including four let,ters and the instant Complaint and Motion, constitute and were intended to constitute a request under 10 C.F.R.
S 2.206 for the institution of a 5 2.202 show cause proceeding.
Moreover, the Motion is, if anything, a request to the Director to issue an immed ia tely effective order under 10 C.F.R. 5 2.202( f) shutting down the reactor while the show cause proceeding runs its course.
TCSE has no right to file a request for an immed ia te-ly effective order.
While 10 C.F.R.
S 2.206(a) permits "[a]ny person (tal file a request with the Director...to institute a proceeding pursuant to S 2.202 to modify, suspend or revoke a license, or for such other action as may be proper", both the decision on whether to institute the proceeding and, if so, whether to issue an immediately ef fective order, lie enticaly
+
within the discretion of the Director.
Section 2. 20 2( f)
~ states:
1243 0i4
_11_
When the Director... finds that the public health, safety or interest so requires or that the violation is willful, the order to show cause may pr ovid e, for stated reasons, that the proposed action be tempotcrily effective pending further order.
Thus, the '.ssuance of an immediately effective order cannot be compelled by a " motion" or petition from a party outside the Commission and, if the Director fails or refuses to issue such an order, his decision is not reviewable by the Co".r ts.
Honicker v. United States Nuclear Regulatory Commission, 590 F.2d 1207, 1209 (1978).
On the o the r hand, the Director may find it necess y to make an order immediately effective if one or both conditions in 10 C. F. R. S 2.202(f) are met, i.e.,
if "the public health, safety or interest so requires" or if the licensee's " violation is villful".
Nuclear Engineering Company, Inc. (Sheffield, Illincis Low-level Waste Rad ioac tive G!sposal Site), Docket No. 27-39 (June 6, 1979), slip opinion at p. 5.
The powers vested in the Direc tor by 10 C.F.R.
S 2.202( f) (and in the Commission as reflected in a parallel provisio,n in S 2. 204 ) have been exercised sparingly, and appropriately so.,
The action taken under these provisions of ten involves (as would be the case here)
"a drastic procedure which can radically and summarily affect the rights and interests of others."
Such emergency powers "must be respon-sibly exercised."
Petition for Emergency and Demedial Action, CLI-78-6, 7 NRC 400, 404 (1978); License.s Authorized to 1243 015.
Possess or Transport Strategic Quantitien,of Special Nuclear Material, CLI-77-3, 5 NRC 16, 20 (1977).
In determining whether to order an operating reactor to shut down, the Director must decide whether the facts alleged and information supplied by tne petitioners " mandated the requested relief in order to provide reasonable assurance that the public health and safety are protected."
Peti: ion for Emergency and Remedial Action, supra, 7 NRC at 404-405; Licensees, supra, 5 NRC at 20-21.
Because of the drar*.ic nature of the remedy, the cases in which a 5 2.202(f) order have been issued are few and always involve extreme situations.
The most recent instance of such an order was in Nuclear Engineering Company, Inc., supra, where the Commission upheld an order by the Director, Nuclear Materials Safety and Safeguards, to an operator of a low-level radioactive waste disposal site to resume its license respon-sibilities immediately, after the.icensee had unilaterally terminated all patrol, maintenance and environmental activities at the site.
The Commission held that the immediately effec-tive order was justified because the ope rato r 's refusal to maintain and monitor the site was willful and constituted a possible violation of health and safety regulations, and because tha t refusal could be reasonably expected to lead to off-site migration of radioactive materials which could expose the public to health and safe ty dangers.
Nuclear Eng inee r ing
. 1243 Di6
Company, Inc. supra, slip opinion at 6.
Another analogous situation was found in Consumer Power Co. (Midland Plant, Units l.and 2), CLI-74-3, 7 AEC 10-12 (1974), where the Commission upheld an order by the Director of Regulation directing a licensee to suspend certain construction activities because an inspection showed quality assurance violations that could have resulted in structural defects not correctable in the future.
Needless to say, the circumstances in this case are not even remotely similar to those presented in those two ac'. ions.
Here, there is neit'her an imminen t threat of danger to the public, as in 1 ; clear Engineering Company, nor a substantial shortcoming that may not be corrected in the future, es in Consumer Power Company.
Therefore,
.e r e is absolutely no need for emergency relief.
In deciding whe ther an immediately ef fective order should be issued it may also prove helpful, by analogy, to review the criteria set fo r th in 10 C. F.R.
5 2.788(e) for determining whether a stay of the decision of a Licensing or Apceal Board should be granted pending appeal.
These criteria, which are based on Virginia Petroleum Jobbers Association v.
Federal Power Commission, 259 F.2d 921, 925 (D.C.
Cir. 1958),
are: (1) whether the petitioner has made a strong showing that is is likely to prevail on the merits; (2) whether the peti-tiener will be irreparably injured unless a stay is granted; (3) whe the r the granting of a stay would harm opher parties;
))q} ))7.
and (4) where the public interest lies.2 While these criteria may not be directly applicable to a S 2.202( f) order, they illustrate the. considerations that would have to be borne in mind before an immediate shutduan could be granted.
With respect to the second of these four factors, neither TCSE nor the public in general will suffer irreparable inj ury if the Davis-Besse unit is not shut down immed ia tely.
Even assuming
( contrary to fact) that the Emergency Plan were deficient, there is not the slightest indication that the Plan will need to be put into effect while the show cause proceeding (if instituted) is pending.
Absent such a clear showing of y
irreparable inj ury, emergency relief must be denied.
- See, e.g.,
Long Island Lighting Co. (Jamesport Nuclear Power Station, Units 1 and 2), ALAB-521, 9 NRC 51, 52 (1979); Public Service Co. of Oklahoma, et al (Black Fox Station, Units 1 and 2), ALAB-505, 8 NRC 527, 530 (1978); Public Service Co. of 2
These criteria are also iden tical to those employed by the cour ts in deciding whether to grant prelimi-nary injunctive relief in judicial proceedings.
Thus, it is well established that preliminary inj unctive relief is an " extraordinary and drastic remedy which si.
uld not be granted unless the novant clearly carries the burden of cersuasion".
Canal Authority of State of Florida v.
Callaway, 489 F.2d 567, 573 (5th Cir. 1971);
the power to issue such relief should be sparingly exercised, and only upon "a clear showing tha t there is clear likelihood of success and irreparable injury".
Schneider
- v. Whaley, 541 F.2d 916, 921-22 (2d Cir. 1976); Sierra Cluo v. Hickel, 433 F.2d 24, 33 ( 9 th Cir. 1970),
af f ',d on o the r ground s sub. nom. Sierra Club v.
- Morton, 40a G.S.
727 (1972); Dorfman v.
Ecozer, 414 F.2d'1168, 117; (D.C. Cir. 1969).
~
12t3 018 t
Indiana, Inc.
(Marble Hill Nuclear Generating Station, Units 1 and 2),
ALAB-493, 8 NRC 253, 270-271 (1978) and ALAB-437, 6 NRC 630, 631 (1.977).
By contrast, the Licensees and the ratepayers stand to lose hundreds of thousands.of dollars a day in added power costs if Davis-Eesse is shut down, thus the third faccor strongly points against the granting of emergency relief.
And, to the extent that the public interest might require a review at this time of the emergency.nd evacuation procedures currently in force at Davis-Besse and other nuclear plants, such a requirement is being met by the ongoing generic Commission investigations of the matter.
In this energy-conscious era, the public interest is not served by a wasteful and expensive shutdown of an operating power plant (particularly where replacement power, if available at all, is most likely to be oil-fired generation'.
In light of the way in which the other three factors point against a shutdown of Davis-Sesse, "it would take an overwhelming showing of likelihood of success on the merits" for TCSE to obtain the ex traordinary relief it seeks.
Public Service Co. of Indiana (Marble Hill Nuclear
- Generating Station, Units 1 and 2), supra, 6 NRC at 635; Florida Power & Light Co.
(St. Lucie Nuclear Power Plant, Unit No. 2), ALAB 404, 5 NRC 1185, 1189 (1977).
Instead of such a showing, our preceding discussion shows that TCSE's charges are gratuitous, inaccurate and misinformed and would stand little chance of being upheld 3
The, Complaint cannot be relied on by the Director as (continued next page)
)
Oz gig J.
by the Director were a show cause proceeding to be in s ti tu ted.
Therefore, ao basis exists for a shutdown of the plant and TCSE's Motion must be summarily rej ected.
VI.
THE REQUEST FOR A SHOW CAUSE PROCEEDING SHOULD BE DENIED Ane Director, of course, is not required to institute a show cause proceeding upon a filing of a request under 10 C.F.R. S 2.206.
All that the regulations require is that
" [wl ithin a reasona_ble time af ter a request...has been re-ceived, the... Dir ec to r... shall e ithe r in s t.i tu te the requested proceed ing in accordance with t5is subpart or chall advise the person who made the request in writing that no proceeding will ins' i tu ted in whole or in part, with respect to his request, be t
and the reasons therefor."
10 C.F.R. 5 2.206(b).
To institute a proceeding to show cause, the Director must " allege violations with which the licensee is charged, or the potentially hazardous conditions or other facts deemed to be sufficient ground for the proposed action."
10 C.F.R.
S 2.202(a)(1).
As established above, Licensees' Emergency Plan meets all NRC requirements.
To the ex tent TCSE believes (continued) the basis for the extraordinary relief requested, in any event, in tha t the factual allegations are not offered in the form of an affidavit to which TCSE has attested under oath or affirmation.
In fact, the f actual allegations are almost totally inaccurate.
. 1243 020
changes are warranted in the emergency planning by federal, State and local bodies or by Licensees, such matters are being addressed: (1) generically by the Commission, (2) by the State of Ohio and (3) by Licensees' own task forces.
A show cause proceeding raising issues already being addressed, which are beyond present Commission regulations, would be inappropriate
~
and duplicative of present NRC efforts in NRR and I&E, and by the Commission's own Task Force.
Accordingly, no basis in fact, law or public policy exists for the issu'ance of a show cause order, immed ia tely effective or otherwise, and the, Director should deny TCSE's request under 5 2.206.
~
Respectfully submitted,
SHAW, PITTMAi., POTTS & TROWBRIDGE f
L a
Bruce W.
Churchill John E.
O'Neill, Jr.
Matias F.
Travieso-Diaz Counsel for Licensees 1800 M Street, N.W.
Wash ing ton,
D.C.
20036 Dated :
July 16, 1979 1243 021
u..
w Appendix A LICENSEES' RESPONSE TO ALLEGATIONS OF TOLEDO COALITION FOR SAFE ENERGY Following are Licensees' responses to the specific allegations of TCSE with respect to deficiencies in the Davis-Besse Unit 1 Emergency Plan.
Most of TLJE's errors seem to have arisen (a) from a misunderstanding of the NRC/ EPA Planning Basis document, (b) from failure to consult the correct Davis-Besse Emergency Plan. document, (c) from misinfor-mation concerning the Licensees' activities related to its Emergency Plan or (d) from an apparent unawareness of the existence of the Ohio S tate Emergency Plan.
1.
TCSE alleges that "the planing radius known as Ihe low population zone (LPZ) in the Davis-Besse Emergency Plan is insufficient and inappropriate to guarantee public health and safety".
(Complaint at 3-8),
a.
Licensees' two mile radius LPZ is established in accordance with NRC regulations in 10 C.F.R.
S 100.11, as set for th in S 2.1. 3.3 of the FSAR and approved by the NRC in S 2.1 of the Safety Evaluation Report.
b.
The Planning basis does not recommend a ten mile radius to be utilized for the LPZ around light water reactors
. 1243 022
a g
as alleged by TCSE.
Rather the NRC/ EPA Task Force recommends a ten mile Emergency Planning Zone for state and local government
^
planning.
In fact, Figure I of the Planning Basis (at page 12) clearly indicates the distinction between the LPZ and the Emergency Planning Zone.
The Ohio State Emergency Plan, in fact, establishes a ten mile Emergency Planning Zone as recommended in the Planning Basis.
2.
TCSE alleges that " Licensees have failed to consider mere than one possible offsite accident sequeace in selecting an adequate evacuation radius, placing nearby residents outside the present radius in unnecessa[y danger."
(Complaint at 8).
a.
Again TCSE misapplies the Planning Basis in comparing it to the Emergency Plan.
The Emergency Plan contemplates a spectrum of potential accidents and the sta-tion's response to those accidents.
The Emergency Plan does not deal with evacuation procedures.
Evacuation is within the sole purview of state and local authorities and is dealt with in detail in the Ohio State Emergency Plan.
3..
TCSE alleges that Licensees ' provisions for offsite treatment of radiation victims are inadequate.
(Complaint at 9-13).
a.
Licensees are not required by NRC regulations to formulate arrangements with two hospitals for treatment of radiological accident victims.
Licensees have established an r
arrangement with Magruder Hospital and, while not required, plans are being made to establish arrangements with a second 1243 023 hospital as a back-up.
b.
The letter agreements cited by TCSE in its Complaint (at paragraph 20) are outdated.
Letter agreements with hospitals, ambulance services, doctors and the Ottawa, s
County Board of Health are renewed each year.
The current agreements are attached to the C.nergency Plan.
c.
More than one doctor is available at Magruder Hospital to treat radiological victims, and Licensees' agree-ments with Doctors Akins, Wagner and Crisologo provide that all t%:ee doctors will be on call in the case of an emergency.
d.
Emergency dril_s have been conducted by Licensees, and Radiation Management Corporation has par-ticipatyd in every one of them.
Radiation Management Corporation has annually reviewed the Emergency Plan and has established medical evacuation plans in the event that evacua-tion is necessary.
e.
Licensees originally aad established emergency transportation arrangements with Robinson Funeral Home.
After Robinson Funderal Home discontinued its ambulance service, arrangements were made with Mid-Counties Ambulance Service, Oak Harbor, Chio, to orovide transportation in the event of an emergency.
This agreement has been renewed each year.
TCSE's allegations with respect to Licensees' arrangements for medical care, emergency transportation and edical evacuation are based on inaccurate information.
f.
TCSE's criticism of the Ottawa County Emergency Plan (Complaint at 12 and 24, 25) appears to be founded in 1243 024.
TCSE's unawareness of the Ohio State Emergency Plan and the revised Ottawa County Emergency Plan (which is incorporated in the Ohio State plan and ' supersedes the Ottawa County Emergency
~
Plan attached to TCSE's Camplaint).
The Ohio State Emergency Plan is presently undergoing NRC review for its concurrence based on NRC's seventy criteria.
4.
TCSE alleges that "the utility assigns excessive tasks and responsibilities to the plant shift foreman, which could not realistically be addressed during an emergency situation."
(Complaint at 13-16).
a.
While the shift fireman is responsible for actions to be taken under the Emergency Plan, the Emergency Plan pr'ovides a breakdown of actions and responsibilities of station personnel to whom the duties have been delegated during a state of emergency.
b.
The Emergency Plan details training requirements for (1) the Emergency Duty Officer: (2) the Radiation Monitoring Team; (3) the Fire Brigade; (4) First-Aid Team; (5)
Magruder Hospital; (6) the Ambulance Service; (7) Oak Harbor Fire Department; and (8) Corporate Support Personnel.
5.
TCSE alleges that "Licentres have failed to comply with NRC guidanc9 concerning the identification of milk processing plants in the Emergency Planning Zone."
(Complaint at 16).
+
a.
There are no NRC requirements for the Emergency Plan to make note of milk plants within a ten mile radius of 1243 025.
Davis-Besse.
The Ohio State Emergency Plan addresses cocedina-tion with, and mczitoring of impacts of any emergeccy on, agricultural and dairy facilities.
6.
TCSE alleges that "the Licensees have failed to conduct emergency drills, in contradictions of NRC guidelines
~
in their own alleged arrangements." (Complaint at 17-19).
a.
Licensees have conducted annual drills as required by 10 C.F.R. Part 50, Appendix E.
All such drills b3ve included the participation of the Ottawa County Sheriff, the Fire Departr:ent of Oak Harbor, Magruder Hospital, the contracted ambulance service an,d Radiation Management
~
Corporation.
The last such drill conducted in 1978 was observed by Mr. Al Januska from Region III, ISE.
~
7.
TCSE alleges tha t " Licensees have failed to quantify estimated evacuation times and expected required times to notify the population in the LPZ. "
(Complaint at 20-22).
a.
The Ohio State Emergency Plan deals with the estimated evacuation times and expected required times to notify the population in the vicinity of the Davis-Besse Plant.
b.
The Emergency Plan reets the requirements of 10 C.F.R.
? art 50, Appendix E (IV)(C) and (D), including estab-lishment of criteria and procedures for notification and participation of local, State and Federal agencies.
c.
Licensees have installed direct, open, continous communication ties with the NRC and have committed to report 1243 026.
any unusual or abnormal occurrence within one hour of the time the reactor is not in a controlled or expected condition of operation.
See Letter from Mr. J.S. Grant, Vice President, Energy Supply, TECO, to Mr. James Keppler, Region III, I&E, dated May 4, 1979.
Thi.e prompt notification link is tested d a il y'.
In addition, radio communications with the Ottawa County Sheriff's office is tested at least three times daily.
8.
TCSE alleges that Licensees have completely omitted from the utility plan any identification of egress routes and their capacity characteristics, and have summarily failed to identify LDZ residents having special evacuation needs."
~
(Complaint at 22-23).
a.
Egress routes and any special evacuation problems are dealt with in the Ohio State Emergency Plan.
9.
TCSE allegec tha t " Licensees have had since at least 1975 to update, revise and upgraded the status of Davis-Besse Emergency Plans."
(Complaint at 23-25).
a.
The Emergency Plan was originally issued November 12, 1975.
It was subsequently revised August 12, 1976; April 7,
1977; May 3, 1978; and June 26, 1979, and is up-to-da te.
10.
TCSE a.2eges that " Licensees' plant has among the poorest operating records of any commercial reactor in the United States, and a consequently greater need for workable emergency and evacuation plans."
(Complaint at 25-28).
a.
The Licensees' operatir.g his to ry %nd the ir actions in light of the Three Mile Island acc id en t were the 6
subject of detailed review by the Director and Commiss'Ja, Ti}is review took place prior to the removal of the May 16, 1979 NRC Suspension Order which allowed Davis-Baese Unit 1 to resume operation.
+
6 e
f 1243 028 e
e
_m e.
APPENDIX 3
... s i.
- r. a : - na-0_,]
ia
..,_ a.
C v.._t. _?.c.c _ r. ht h u.C r r..se.. w..e.G t.ir a m. n=.v.
m.
. r.
(10 CFR Part 50 Appendiz I)
A.DEQUACY AND ACCI?TANCE OF IMIRGINCY r.n, hn.u~ h1G
- n. :0 v ND N*v C r en. 2 r.aC Lvm. rS a
AGE' ICY:
U.S. Nuclear Regulatcry Co==ission ACTION:
Ad rance Notice of Proposed Rulemaking SG"/.ARY :
"he Nuclear ReSulatory Cc:::lission is considering the adoption of additional reSulations whi_.. will establish as c
..d_ _' ' _* c.s o.' o c w a..~ - a =. C ' o c
e.- a_. 4_ c r. _i.n a..- a. _s s a_ d e.. e. 3 =..m y y
.-a.ga_
ass.--
a.c'_o1 _4 n ' ". a. '_ _' r. _d '..v c '. " *. ' =. _-
,., a.=.-
c y
_.d s '. c'. a_
.= =.=.. c.=...... = y c _.
c.'
b o'e h.. h e ' _4. e...< e a. - ' ' - ~ e~ _'
- c. ~ _,.
_. m _4 s s ' o r. d s
_4. ' a.~. s. e d
_4 r..~. ~. =_ _' v'.. 3,o t.' 5. '_ _' c c.,,
_.e.a.
e. a.
s e
e c c e. a... an C a C m a s. n.. J_c
. o m.
- a. n. u. 2.. a s.Po -
- a..='.? s. a. "..J./ a p 1 an.e n _.__- a_.e. _.
e.m.
C.,2
. s 3
,3 _ c.. 3,
.y=..
c o 7C u."." a 7 C a
_4.*.
.C ' c~ ~. *,
c".. d ', C '.2. '_
1
-._-_. fl.ees-_
"' a..e.
c_
s._.. m.. _ m.
3
...e o
_t g go g.4 c a.
c.e an ac. a
- c. _ A.._ _ a. a...e a.
c.m.n_.
., C.. -
o a.
a - a.a....
_ g.-
3 w
c J..
- a r,,I.
e, *y* a..** a *. # ~ *.
g
".U ^. I a c".-
.#' A e_ _d _I _4 '."'./ s E". -
- C.-d#**E'*##.'.a h.=*."%.*.3S.'.'.'
". b.. A.
- t
~.
,,s.
_i -. g.
Pa. a.
,*a===._J.e..c. _ g.
.c. =. a. ' r. s J
.C* c*.a.
g.4 i g g g_1
- p=
24
- J
.a m.
c a. o.
~
c.
p y
y-.
..w..
4
- m. s e w.. o. _C
- s. m.
4 1... a 2 e
_s....a._..a.
...e..
... r.t a,--n...3 c _- a.
-ug g 3 c l a ".' *.* '. '*. S *. (h
- : " s...'"..=_.~
an
_e
_e e. _. _e.. _
. w. a. v. a. e. s e 9-
=.. a.._. _t, _ e " ).
4
.._,.. _..e..t. _..e..
?..m.a 6.. a..r.
,- e-a n *w s c a, n a. a. -., '_.3
- w. a..e. a._4as..a s s. 1 1 4 wa w.,...
w,
.q 3.,.,.- m. _. c. _-..
. w. a. g.,.._ e.._ 3,4 g,
...e.. i.,. _ a. c.,,
.: a. 3...,.,,,.,.
e
.... e _ _ a..:
._c.
,s w.
.e.... g..
~ _ ~., c. e. :.,i,.e.
_ _ a.a.e _a.
-- : us _ _,.
..3
=_7..;*...==_f.=.
f.mem,e- = e 7. =,
- 7...;.=.,* 7; i......-
,u..,
...-,.a.
..r
- ..=-.. a_ _ a.
.a n
_a..
DUPLICATE DOCUMENT
..__a..<,,
?_,,._a__.,.,
~. ~., c. C : :.
Entire document previously
... ~
entered into system under:
- 7. 7. 0, 9, M
[
1243 f29
^uo No. of Pages:
G)
\\
Toledo Coalition for Safe Energy P.O. Box 4545 Wfe Toledo, OH 4 3520
-d-#-
(419) 243-6959 April 24,1979
~
.e Mr." Jarres G. reppler, Director Nuclear Regulatory Commission, Region III h-Of fice of Inspection and Enforcement gpGQ %su@d311
, {j Q d f
799 Rooseve1t Rd.
Glen Ellyn, IL 60137
Dear lir. Keppler:
'.'e have fo710wed with considerable interest the actions of the NRC and Toledo Edison, operator of the Davis-Besse nuclear plant, since the Three Mile Island disaster.
After reading your comments in the April 20, 1979 Toledo Blade concerning personnel performance at Daviss Besse, we are greatly concerned about the irresponsibility of the NRC t
. decision to allcw Davis-Besse to go back on line before numerous safe y questicns have been answered.
Our concerns have been redo bled by the' April 19 findings of the Ohio Pub'.ic Interest Research Group (OPIRG) that documents the gross in the event of a serious inade:;uacies' of emergency and evacuation plansThe NRC appears to be an accom accident at Cavis-Besse.
situation, allcwing a less-than-public spirited utility to return to power generation while that utility continues to maintain incorpetent staff and substandard emrgency preparations.
Therefore, the Toledo Coalition for Safe Energy demands that the folicwing steps be taken by your office immediately:
That Toledo Edison officials be restrained from reopening Davis-Besse until such time as all possible operational problems, human and mech-1/
anical, have been corrected; That revised and updated evacuation plans be posted in vi:ible 2/
public places within a 50 mile radius of Davis-Besse within 30 days of reopening; your receipt of this notice, and prior to D-B's That a full-scale disaster drill be conducted within a 10 mile 3/
radius of the plant prior to its return,to power generation; That all consumers in the Toledo Edison and Cleveland Electric 4/
Inluminating jurisdictions receive a complete written description of emargency procedures with their last electr.ic bills prior to the startup of Davis-Besse; That these and other matters becorre the subject of ful and q p 5/
cpen public hearings initiated by the NRC prior to 0-S's str
, (\\
1 be Your earlest written response to these urgent requests wt IN3 030 wabf f
(..'
(
s.
e 1;r. 5s'.cs G. Ycypier
.~ 4/24/19 Pg., 2 greatly ' appreciated., Thank you.
f Sincerel C
- /<
sG
.L ge er Cha[ryn TCSE Legal Action Comni ttce V
.V Members, U.S. tiuclear Regulatory Comission cc:
'n'ashington, D.C. 20555 Senator Iteward Metzenbaum
~
234 Sunnit St.
Toledo, OH 43604 12t3 03t t
e
=
O P
e e
d
U Ni t ( O STATc3
' ' 4s
,tJt>ctc An ncGijtAroity cc:.v.utticN
. zjf f *,,
riccion ut
- Cq.
is t nou.c vct.r nono 7;-
.[
.f.'*'.*-
o t.c N c u.v u. it u n o e s soi s.
n e
May 17, 1979
..s-
. ~
Mr. Tert,/ J. Iedge, Chai rman Ts ledo Coalition for Sa fe Energy
((.LL.[. u. : i ik {
P.O. Box 4545 k
8 Toledo, Ohio 43620
..i-O L 1L Dea r Mr. Lod,e :
Tidis is in reply to jour letter of Ag.~cil. 24, 1979, identifying steps resu=ption of operatiuns schich you believe chould be taken relative to of the Davic-Ecsoc nuclea r plant.
As you p rob ably knov, based on in fo rca-tion obtained to date from the Three Mile Island accident, the SRC issued an Order to all operating reactor licenaces c ning Babcock and Wilcox includ ing ravis -Besse, requiring C~2pany cucicar steam supply systems, in operatin g procedut es.
A copy certain decign =odifications and changes provided as an ehelosure.
The of the Order to Toledo Edf uon-Cc=pany is reactor vill not be pernitted to return t() operation until the actions specified in the Order have been cc=pleted to the satisfaction of the NRC.
With respect to the actions specified in your letter, uc are treatingformal Hea for a your Ictter as a requert 10 - Chapter 1 Code of Federal of the NRC Eoles and Regulations (Title forwarded f our Ictter to our 2cadquarters Regulations).
As such, I have staf f for consideration of your raquest.
Yo u can e.~ pect to hcar directly from them regarding this catter.
If you have additional. questions regarding the NRC'a actions in this
=atter, please let ca know.
Sincctc17,
0
$..s.,h lT T h.b k ff s c. r er Direc t o r Encidsure 0rder to Toledo Edison Co=pany bec v/o enclosure:
gm\\
Dudicy Tho:cpson,,XOOS n
).'\\\\
fi\\\\Q p
- s m)\\y g
go 79$8 8&bLL
P.O. Box 2091 Toledo, OH 43603 May 23, 1979 Mr. Stephen Burns Office of Executive Legal Director Nuclear Regulatory Commission RE: Complaint of Toledo ylition for Safe C 1717 H Street, N.W. Washington, D.C. 20555 Energy Cear Mr. Burns: I am writing in confirmation of our telephone conversation of Monday, May ci, at which time you apprised me of the fact that your office is treating my April 24 letter as a request for a formal hearing per 10 CFR 92.206. For the record, I am ratifying that determination on behalf of my client, the Toledo,Caalition for 3afe Energy, and wish to preserve TCSE's procedural rights to properly pursue this matter. Enclo: 2d per your recuest are the April 20, 1979 Toledo Blade news article referenced in my April 24 letter, and the WednesdayT April 18, ~ 1979 news release of the Ohio Public Interest Research Group concerning inadaquacies of evacuation preparations at the Davis-3 esse I Nuclear Power Station near Port.lir. ton, Ohio. You are douatless aware that Davis-Besse is a Babcock & Wilcox reactor, closely related frca a design standpoint to Three Mile Island I. It is thus understandable that the Coalition might draw unsettling conclusions from tne juxtaposed cocmenh of James G. Keppler of the NRC Region III office, and the publicly-proclaimed inadequacies of emergency plans. In the coming weeks, legal research people from TCSE will be ar. tempting to verify the existence of other questionable aspects of both the utility and State of Ohio emergency plans for Davis-Besse. As all of ti.is help will come from volunteers, we ask that you allow us the time to take up our inquiry where OPIRG left off. While I will not reiterate all of the elements of relief which my client seeks through the complaint process, I hope that the NRC will be able to make a policy determination that the safety aspects of this poorly-managed reactor override the economic considerations which may force Davis-Besse back on line before emergency contingencies are fully addressed. Since rely [' .,'t,,. lll.~ g- / o j Terry (J Lodge ,g, Attorne/ v .u Toledo caliticn for Safe Cn enc 1243 033 7 %f>SA$ 2 97
Ob50 N d !C [h.!5b.33 b[ bbi$bh.:-!U -1 G.40 W f h STATE OFFICE 65 S. 4th ST. COLUMSUS, OMIO 43215 - [3141 461-0136 i (> OTHER OFFICES: CSERLlr4 COLLEGE, WITTEN3 ERG UNIVEF.SITY, UNIVERSITY OF DAYTON, WILMINGTON COLLEGE, CAPITAL UNIVERSITY FOR IMMEDI ATE RELEASE Vednesday, April 18, 1979
Contact:
Janis White 614-461-0136 614-299-8527 Kathy Vestby 216-775-5137 216-775-5283 EMERGENCY EVACUATION PLANS AT DAVIS-BESSE PLANT INADEQUATE Plans to safely evacuate the residents of the area near the Davis-Besse nuclear pcwer plant in case of a nuclear accident appear to be inadequate, according to the Ohio Public Intarest Research Group (OPIRG). The group has called for a full scale evacuaticn dr!!! before the plant reopens. "We have discovered that neither the utility nor the state e.mergency plans meet all the recommended federal guidelines and that the two plans d,i f fe r in many aspects which could affect the smooth functior.ing of an actual evacuation," said Kathy Westby: nicarch coordinator. "Governrrent and utility persennel charged with responsibilities in the plans do not always knew what those responsibilities are," Westby said. Oeveloping and implementing emergency evacuation procedures are the joint rn cD respcasibility of the Toledo Edisen Co., the operator of the Davis-Besse plant, e and the Ohio Disaster Services Agency. The utility plan, filed with the Nuclear g ~ Regulatory Commission, covers emergency procedures within the plant and plans for off-site support by government agencies. The state's draf t plan, inccmplete at: hough the plant has been in operation, establishes the roles and responsibil-O -mre-
2- .I ities of government persennel in the event of an emergency. According to Vestby, the only employee of the Ottawa County Disaster Services ~ Agency was not aware that he is supposed to play a moJor role in evacuating residents and arranging for their relocatio'n. In;tead, he believed his role was a minor one, simply to act as a liaison between the plant and state officials to provide needed support after the accident. One fire of ficial said, "We don't have any of-that wicked stuff (dangereus radiation] here (at.the plant]." He told CPIRG researchers he had fc.md this opinion based en informatiwn ha had received from Davis-Besse officia s. The utility company is required to contract with two hospitals for the provision of emergency medical services. The principle hospital identified in the utility plan is the Magruder Memorial Hospital in Port Clinton, approximately eleven miles from the plant. They are only equipped to handle up to c0 serious radio.ogical victics. Tne second hospital named in the plan is the University of Pennsylvania Hospital in Philacciphia. An administrator at Magruder however, thought th e second hospital was probably St. Charles Hospital in Toledo and was totally unaware of the role of the University of Pennsylvania Hospital. "Given the fact that the primary hospital is within the possible radiation zone, and tnat the ocher one is almost 400 miles away with no apparent plans for transporting victims, makes us question the adequacy of medical provi > ions in the plan," said Vestby. Current plans would evacuate residents within a 2 mile radius of the plant, althoug5 there ha s been some recent discussion of extending tnat to a 20 mile rad ius. "A full scale nuclear accident could affect an area the sice of Pennsylvania. What good muld these plans do us then?" said Janis White, Director of OPIRG. "Even if a less serious accident occurred, it could become necessary to 243 035 -more -more -m re-
( evacuate the Toledo area' which is only 35 miles frem the plant," she added. The state draft plan equates nuclear evacuation precadures with those used in the event of a natural disaster s ich as floods or hign water. ~ ' iuclear accidents and natural disasters are not equivalent and cannot be Differences in warning tiires and signals, as well as handled in the same way. the health hazards connected with radiation exposure require special considers-ef on for a nuclear emergency. By comparing the two, the state is defenstrating its lack of awareness of the real dangers of a nuc' lear disaster," White said. "Neither plan meets all the recer., ended federal guidelines," Ves tby added. "For instance, estimates of expected accident assessment times, evacuation times, or traffic capacities of evacuation routes are not mentioned at all in the plans." "CPIRG questions the effectiveness of tSese plans. Our research indicates that they are ambiguous, contradictory, incnmplete, and un-tes ted," said Ves tby. "A fe.v of the agencies listed in t e plans have held their own practice h drills, but no coordinated, full scale drills have been conducted based on the pl ans," centinued 'a"ni te. "The public has never been told Scw they will be con-cacted or what they shculd do in case of a nuclear emergency."
- he states where nuclear evacuation drills have been conducted, evacua-
"In tion plans have had to be rewritten to reflect reality," she added. "Je call on Toledo Edison and the state of Chio to schedule a full scale evacuation drill befors the Davis-Besse plant is put back in operation," said "They have accepted the public responsibility to protect Ohioans - we 'ah i t e. he.ve the right to see if the plans en paper will work in practice." OPTRG is a statewide, university based research and advocacy organization cencerned with censumer protection, environmental quality, human rights, government respcas iveness, and corporate responsibility. 1243 036 State. and Utility E.dcuation Plans: o Are I hey inapaequate. Utility cen,.anies and the state share the respcnsibility for developit$g and Implementing emergency evacuation plans in the event of a nuclear accident. The !!uclear Regulatory Commission requires the utility ccmpany to file a plan dealirig with both in pi' nt and off-site procedures. The state plan delinenter the roles and responsibilities of off-site agencies involved in evacuation pro-cedures. Evacuation plans for the Davis-Besse nucicar power plant have been developed by the Tcledo Edison Oo. and the Ohio Disaster Services Agency (draf t plan). OPIRG has analyzed whether the Toledo Edison plan and the State of Ohio Officials named in the two plans were also con-plan meet federal standards. tacted by letter and/or phone to find cut what they believe they are supposed to do in case of a nuclear emergency. Failure To Meet Federal Guidelines Both plans f'il to meet sema of the reccmmended federal guidelines. The utility plan does not contain: the expected accident assessment time the expected time required to notify the population estimates of evacuation times for the areas which would be affected estinates of the t ffic capacities of egress routes arrangements with contigucus states The state draf t plan does not centain: planning coordination with nearby states a population chart by sectors around the plant an acccunt of institutions and transient populations which may impair mobility egress routes and their traf fic capacities plans for yearly drills and exercises Ambiguities and Contradictions The folicwing chart compares what the plans state should happen with what the officials interviewed believe they wculd do: THE OFFICIALS SAY: THE PLANS SAY: 1. SHIFT FOREMAN Utility Plan: evaluates accident, no-wcuid contact Taiedo Edison - company tifies off-site support groups in case would then contact sheri ff. of emergency, contacts other plant of-1243 037 ficials, county sheriff, medical assis-tance and fire depart:aant if needed. State plan: does not specify who from
plant notifies off-site support groups. II. CCUNTY SnlR8FF Ut il i ty Plan: contacts C .ad 9t-would contact relevant agencies and help tcwa County Disaste - Scr. ices esacuate people. gencies, initiates emergen.c7 no-ti".ation syst.', sets up road bl,cas and other * . cation pro-ced +. State Plan: notifies all county and state agencies involved, notifies residents ir affected area, desig-nates road blocks. III. OTTAVA COUNTY ENGINEER U t i l i ty Pl an,: assist in traffic would help evacuate, noti fy public, set control and back-up communica-up road blocks, assess equipment and tions. get more help if nieded. State Plan: provide barriers, make equipment and manpower available, support evacuation, assist in door to door notification. IV. OHIO DISASTER SERVICES AGENCY Utiliev_ Plan: work with sheriff to have prepared draf t state plan - doesn't cetermine evacuation routes and deal with evacuation routes, does relocation centers, arrange for have list of potential care centers food, lodging, and madical care. for Ott wa county. State Plan: not mentioned in text. V. OTTAVA CCUNTY DISASTER SERVICES AGENCY Utility Plan: not mentioned in consists of one employee who believes his role is after the disaster, would text. State Plan: evacuate residents, contact Ohio Disaster Services Agency identify and prepare evacuation for help, said he would play minor centers, arrange for 10 days sup-rol e, port, coordinate emergency planning with other county agencies. VI. FIRE DEPARTFENT Utility Plan: contacted if needed. would help put out plant fires (hewever State Plan: assist sheriff with co not have any ;pecial equipment puolic notification, assist in at Department for fighting radiological evacuation procedures and fight fires), would help with public notif1-any fires. cation. Vll. MEDICAL SUPPORT A. AMSULANCE SERVICE Utility Plan: provided by Robinson no longer provided by Robinson Funeral Funeral Home, Oak Harbor. Home - sold to Carroll Tcwnship Emer-State Plan: not mentioned in text. gency Medical Service - unable to find supervisor there.
- 3. MAGRUDER MEMORI AL HOSPITAL, Port Clinton Utility _ Plan:
radiation emergency could handle up to o0 serious cases of informala8ree-038 area ready if needed, have special rad ia tion exposure, 124
ments with other area hospitals equipmant. S t a te_. Pl an: not mentioned in text. to handle overflow. C. UNIVERSITY OF PENNSYt.V7dtlA HOSPITAL., Philadelphia U t il i ty_ Pl an_: second facility named not contacted (Magruder Hospital ad-ministrator not aware that University to handle radiation exposure, cases. State Plan _: not mentioned in text. of Pennsylvania Hospital is the back-up hospital). D. RADI ATION PANAGEMENT CORPORATION Utility Plan: provide training and did not respond to. 0PIRG ietter. ~~ and evaluation of emergency adical plans. State Plan: not mentioned.in text. Vill. TOLEDO EDISON CO. U ti l i ty Plan: release public infor - Public Relations staff parson knew little about plan or procedures. mation. State Plan: not mentioned in text. Scme other agencies are listed in the plans as playing secondary roles, but were not contacted by OPIRG. (~ip? I CHO FU5'.!C lNTEREST RESEARCH GRCUP 4/17/79 461-0136 1243 039 t e e e 4
u m.. r,,. p.m u i a s,o., ;,C " O ' W mm m ,. m. -..,. m i uu /-t Davis-Besse s Onder NRC Studv / ""t r w 5 suped t tus Ha senc! paung DasBee kre so Number Called speific valve at the facility. I. stud of worrisome tbt an NRC Ins;ector re-j tur=28 " ce "=ct'v'!ve. te turn
- cent!r urad Mr.Kerpler to shut ce Unusually High -
S off two other valyes - a mistake that plant dcun and keep it closed until the -.? partially inactivated the reactor's situation could be ccrrected. ~ = ~ By SUCHAEL WOODS. ~ s.6.so.m se%r crucial emergency core cooMeg system. Davis.Besse. currently remains shut ~-~ WASHINGTON - The U.S. Nuefear-The Toledo Ed! en Co., which h'as down, foUowing a scheduled outage for = ?. Regulatory Commission is trying to de. charge of operations at Davis-Besse, maintenance. Mr' Keppler said he dos termine why the Davis-Besse Nuclear may be fined for'the incide::t, Mr. Kep-not intend to order Edison to keep the Power Station near To:cdo conticues to pler said. Toledo Edison is co4wner of. plat shut - partly Locause of as-M r! red by an twsually high number Davis-Besse, along with the Cleveland surance from Toledo FAison President 'W Jch: Wi21=r:a that cparction win not of personnel errors. Eictdc IUumirating Co. James Keppler, diractor of NRC's Davis Bcsse has come under sharp resums until the personnel problem is Chic 2&o regioral office, said the fre. NRC scrutiny in recent wens in tha solved. " ;, h; a quency and potential seriousn:ss of mis. Ofterm:th cf the accid;nt at the Three No Action To Prevent Restart takes made by plant personnel have giv. Stile h!and nuclear power piant near NRC hs taica no actica that wculd en Davis-Bcsse or,c cf the poorest repu darrishurg, Pa. - prevent ~ Edison from restarting the b _,= taticas for operator precision in the re. Davis-Besse s reacter is a sister to the plant immediately. Technically, allI
- .7 gion.
reactor at Thrw Mila Island, bcth hav Edison would have to da is notify NRC E ts phns to "go critical" wit The Chicago regional offlee ontsees tog been built by the nue: ear engineer of 21 nuclear power plant.'sprea/. through log firm sf Babcock & Wilect. In addi-plant. a brcad section of the Midwen. tion, NRC has ide::tified malfunctions A::other factor, Mr. Keppler said, is [ Many of the personnet. errors at similar to those at ~' tree */ile Island that Edison personel at the plant doi Davis-Besse have been minor, Mr. Kap. that occu-red in less se:ious form early sem capable of cperating the facility in k pler said. But others have involved m the operating life of Davis &sse. a pasde fashion. crucial safety systems, where mistakes Shotdom: Urged U be were to rate operator per k carry the potential for the most serious e plant s conW.rg pdem with formance due on a "passdad" basis,[ Linds of nuclear reactor accidents. personnel errors, which 5,.r. Keppler dis-Mr. Keppler said be would confer a t~~ Torned Off Wrong Valves cussed during an interview nursday, passing grade. Mr. Keppler cited, as an iUustration, are an additional factor. one incident last month in which a plant Mr. Kepler said that mistakes by per-Turn to Page 7, Col. 3 t.W n t u= w.3 s, _ s. w, m.a. u. . _ _ __ _.,.Q.Q y? [. h. 0M A-n ?hn, ~ p. 5 THE' BLADE. TOLEDO, OHIO, FRIDAY, APRIL 20, 1979 { Davis 4 esse Personne Errors Uncer Stucy [p Besse shut down until he is ce Contin _oed fron1_Eint_P_ag Besse in the months foUowing s*artup in operation can resume safely. t At t,1977. ut he also m. dicated 'that on a scale Performance of plant personnel has E ,, f A, B, C, D, or F, he probah!y would , t personnel errors have remained improved recently, Mr. Winiamson said. N
- (cade plant personnel perfor nance with n;usuany high at the plant and show E h P*
dh IS Eu (ndication of dropping off after two are former navy personnel with reactor E a Tr ~ w nf = ched3RC., years of operating experience. ~ I held here April 5, a week after the Poor Motivation, Discipline Th ee Mile h!and incident, mention Assaring Complete Safety gg Davis-Besse's continuing aroblems. John The reasons, Mr. Keppler said, are Davis, acting,directoir cf MC's'officeo rplesing. Amo::g the possibilities Some of the plant operators will be ps ~ inspection.and enforcement, noted dur. eing considered by NEC are inadequate trained shortly in new procedures stem micg fmn the Three Mile Island inci-ing the meeting "If we did have a ratq raining of the operato;s, poor mctiva. t dent. Trm, g win be on a computer m irg sysics of A, B, C, we would put,tfon, and poor discipline. Iror.icaUy plantDavis.Besse C on this / L Ucensing examinatics fcr reactcr opera. clear facility in Lynchburg, Va. ' a betterglant." Mr. Keppjer ackno mat.per. tors, Mr. Keppler noted. n'e primary concern at this point is
- sonnel errors 7o te.N.w*be more fre-Mr. Kepp!cr said that Edison reali
- es assuring complete safety of the plant a=d not the eccnomic impact of the
- cent during the early months of opera-that there have been problems with per. shutdown, he coted. Mr. Williamson nid ti:n at any n:w atomic power plant, son:21 at the plant and has agreed to when the staff is new and relatively :2bmit a plan for correcting hem.
it probably w:.!! te a ma:!cr of weeks, inaperienced. And, indeed, p.ersonnel Mr. WHiir.mson said Thursday be has rather than days or months. before the errors were more frquent at Davis made a personal decision to keep Davis. plant is set to resume operations. i
~. ..' JWiE ,1 uz3 7;:.. .: N-f. s. ., 1-xt e t No. : 50-346 t. f. 0{ 9PI'st' O" nq e ~ N kn> lir. Terry J. Lodge Toledo Coalition for Safe Energy .P. O. Box 4545 , Toledo, Ohio 43620 ~~
Dear l'r. Lodge:
...This letter is 'sent to acknc'.'dedge receipt of your 'petitiim on. oenair or - the Toledo Coalition for Safe, Energy requesting that the Office of Inspection and Enforcement issue an order that.the Davis-Cesse nuclear, plant not be restarted until certain.ccergency and evacuation actions are taler. by Toledo Edison and public hearings are held. Your petition has been referred to the Director of.i'uclear Reactor Regulation because the subject matter of the peti. tion.is within the jurisdict. ion of t. his ggg; g, r.10 CFR 2.206 of the Comission's Your petition is being treate nc regulations, and accordingly, appropriate action will be taken within a reasonable time. I enclose for your infomation a copy of the notice that is being filed for publication with. the. Office.of the. Federal, Register. ~ ~incerolv 0ne.u. 5cd hy. H. R. D enku ~ Harold R. Denton, Director Office of tiuclear Reactor Regul a tion
Enclosure:
fictice of mgq& , qGS W@ of \\ JU c'g@f? 1243 041 79p8.%Pz67
- 9....
- r.,,.g 1
U79 ,.f Q,.~,.. : ~ ~ -Docket i;o. : 50-346 ~ ~ Mr.1.cwell E. Roe g
- MIQ Vice President, Facilities
...grfi) m. 2 i.',y v "].11 #i Development Toledo Edison Ccepany Edison Plaza 300 Madison Avenue 43652 Toledo, Ohio,
Dear Mr. Roe:
I enclose for your inforration a copy of a petition filed on behalf of 'the Toledo Coalition for Safe Energy which requests that an order be issued that the Davis-Sesse nuclear plant. not be res tarted until certain actions. ~ are taken concerning ew:rgency and, evacuatjon prbcedures and public hearin The petition.is being treated under 10 CFR 2.206 of the have been hald. Conaission's regulations, and accordingly, appropriate action will. be taken en the petition within a reasonable tine. I also enclose for your inforration a copy of the notice that will be filed for publication with the Office of the Federal Register. Sincere'y, Ori h31 Sisc:-I by t H. R.,D e nt on Harold R. Denton, Director Office of Tjuclear Reactor . Regulation
Enclosures:
1. Petition 2. I:otice cc w/ enclosures: Seenextpahe e f\\ WF.@q@#W y&" ~ 7 9$7.U@@l 7 ^
Toledo Edisor. Company cP.U/ enclosure (s): ...-. 7 I'r. Donald H. Hauser, Esq. Director, Technical Assessr.cnt The Cleveland Electric Division. - Illuminating Company Of fice of Radiation Programs P. O. Box 5000' ' (AU-459) U. S. Environmental Protection Agency Cleveland, Ohio 44101 Crystal Mall #2 Gerald Charnoff, Esq. Arlington, Virginia 20460 Shaw, Pittman, Potts U. S. Environmental Protection i.gency and'Trowbridge 1800 M Street, N.W. Federal Activities Branch Washington, D.C. 20036 Region V Office ATTN: EIS COORDINATOR 230 South Dearborn Street Leslie Henry, Esq. Fuller, Seney, Henry and Hodge Chicago, Illinois 60504 300 Kadison Avenue Toledo, Ohio 43604. Mr. Robert B. Eorsum Ohio Department of Health Babcock & Wilcox , ATTN: Director of Health T'uclear Pcwer Generation Division Suite 420, 7735 Old Georgetown Road 450 East Town Street Bethesda, Maryland 20014 Col umbus, Ohio 43216 Ida Rupp Public Library 310 Madison Street Port Clinton,0hio 43452 ,,, g p( FM, Jj p'4: g.g ,, m. m u President, Board of County ' " ' ' ~ Comissioners of Ottawa County Fort Clinton, Ohio 43452 Attorney General Department of Attorney General 30 East Brcad Street Columbus, Ohio 43215 s Farold Kahn, Sta ff Scientist Po.ter Siting Commission 361 East B.oad Street Columbus, Ohio 43215 m ed
7S90-01 ~ ' ~ ;i:,- UtilTED STATES OF A'iERICA .RE liUCLEAR REGULATOP.Y CCF.'il SS10tl . TOLEDO EDISON COMPAliY AfiD ) 1HE CLEVELA;;D ELECTRIC ILLUM1:iATIt!G ) COMPAt1Y ) DOCKET li0. 50-346 DAVIS-BESSE NUCLEAR POWER STAT 10tl, UtilT 140.1 REQUEST FOR ACTION UNDER 10 CFR 2.206 Notice is hereby given that by petition dated April 24,1979, the Toledo Coalition for Safe Energy _ requested that an order be issued that the Davis-Besse Nuclear Power Station, Unit No.1, not be restarted until certain actions are taken concerning emrgency and evicuation pro-cedures and public hearirigs have been held. This petition is being treated as a request for action unde 10 CFR 2.206 of the Comission's regulations, and accordingly, action will be taken on the peitition within a reasonable, time. Copies of the petition are available for inspection in the Cormission's Public Documnt Room at 1717 H Street, N.W., Washington, D.C. 20SSS_and in the local public document room at the Ida Rupp Public Library, ~310 Madison Street, Port Clinton, Ohio 43452. FOR THE NUCLEAR REGULATORY COMMISSION. PSY-i Harold R. Denton, Director Office of Nuclear Reactor pn0@0 MJh\\ 0jt Cited at Bethesda, Maryland, this 1st day of June 1979. 1243 044 ~' ]9f)f(ffdhb)h
9 S H Aw, PITTM AN, POT rs & Taowa m oc E I000#4 s i n t_ C T, N. W. WA S HING T O N, O. C. 2 O d a G~ ' ' [. 0 e. .:u.-: 17 0 2 3 3 3 P 4 8 0 0 .~ m a =e s a r e,s. mo rt s LT C v C od L. M C LT I C 4 ~ S T C wa=* t. Pe t T u s es oCau O.AutoCE G E C 8 G '. F.1 h 3 = D ee OG C sOM w C reg CL 9CggCereCR 31 C P =. w 0. PQ t T S b 1 C P" C M 8. M W FT L C R w o m t ee m Q P M. e n o w e6 8202)294 0694 & A > C
- e F 4 0.
C L en e. O C as a m u G r P e P en e t.s p a uC ETweCR J Ate C S 0. os aas te pe se c e C ae f C. Z A *e L E N
- o. T e m= O t a v m a *e t o se
~ G E C A G C **. m o '. L
- S. J 4 p
- C w A 4 0' C. G a L C he IEEEE sGMN e. m m e = C h a h C C 4 pc 0 C a t 0. n c o e s u s a m W C C w. C d w
- C om e L L LaWA4
- 4. F a da a A pe O 3 9 *P69 3 ISM Awbaw wS4 L C S t e t A. ee eC = O L L O N, J A.
pe a fia $ r. T a a va C 5 0. osag wanfaw O.esatt veCTCe4M J.PCAnaNS CA O LC
- S H A* b^t'#*
a sC es s e* O J. a C '* C At t JOMM w. O'se C IL L. s 4 jat C. S at e t eG J AY A. C PSYeC N ~ e a se g a a n me. n ; 5 *,o1 fg f R A N a bite O. C atJ G C O as C C v. a t t C w. s 4 c C c aG C O. C ac at CY, J A CHN**.SHASON wme,haaLfCao 6v*ogog aeeC m a C L C. M A T S
- O w A m p 9. C R O C L A ** O F A C O A. L*1 T L C T ee G es 4 5 M. Der C C 4 *s eC m r e & D C A a S *= L S SWLAN 4 P A(a SON COUNSfb M *T.w,a w C L e.e a r.C O, J 4.
.S t C v C N w. t u.C. A S -a a v G C,.. eC . se O t. a u C A L.u e.J. w C l 3 0.A.2 O J u n e.8., 1979 AN L e. ** C S T L 2.*
- C..' 84 C..
sto Sa.o,Es . L
- u n., v s....C =
w M,.. 1 = t -C -a s a.s a s a-e 5 -. se. seM-L. e A .J.. S a t t L C M A a f. e S C L FM t LIP J. os a ttv CT \\ J C M N A, one C ULLo w ;*4 A A F L. R e C et >9 A N Jae C S 1-C. s LCr.M aar Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Co:rcaission Washington, D. C. 20S55 Re: Day i.s-Besse Nuclear Power S ta tion, Unit No. 1, Docket No. 50-346
Dear Mr. Denton:
By letter dated April 24, 1979, the Toledo Coalition for Safe Energy has made several demands related to the operation of the Davis-Sesse Nuclear Power Station, Unit No. 1. This letter is being treated by the Director of Nuclear Reactor Regulation ~ as a request for action under 10 C.F.R. S2.206. The first demand, related to "all possible operational problems, human and mechanical" is. so broad and vague it must be dismissed; its lack of specific.ity permits no reasoned respohse by the NRC Sta f f. The next three demands are all related to emergency pla ns, and are actions which are neither required nor authorized by MRC regulations; as such they could be considered, if at all, only an a request for rulemaking, and not as actions relating to the status of a particular license. The fifth and final demand -- for a hearing on the pr evious four dema nd s '-- is thus an empty request. W t 9 1243045[s j M,2 ~19 $ bl5@ 2%
S H/l//, P li T!.'. AtJ, PO T I S T RC','.' O R ! D G E Mr. I!arold R. Denton Page Two .J,une 8, 1979 ~'.-i f ; .,Accordingly, the Licensees respectfully submit taat the Coalition's request should be denied. Sincerely yours,' s f i Br W. Churchill Councel for The Toledo Edison Company and The Cleveland Elec t r ic Illuminating Company, Licen se e s Bh7C:cp cc: Toledo Coalition for Safe Energy 1243 046 e 9 ee e M
.(O 'f U ' "" f ) SR gs M,3c,wri 7 9 i g cm3 hsd3 4 P.O. Box 2091 3 Toledo, OH 42603 cc6 t,cn 0 3 July 9, 1979 N \\ c, Mr. Harold Centen, Director Office of Nuclear Reacter Regula' tion RE: Davis-Basse Nuclear Power Station U.S. Nuclear Regulatory Cearnission Occket No. 50-346 1717 H Street, N.W. Washington, D.C. 20555
Dear Mr. Center:
Thank you for your correspendence of June 27, 1979. I t:elieve that the enciesed mignt be of assistance to the Cec:nission in revisiting its decision to allcw Davis-Besse to restart. Please find herein a verifie..ccy of (1) a motten by 'de Toledo Coalition for Safe Energy to this C:.c:nission seeking a preliminary ice .iunction or any NRC crder having the practical effect of cicsing dcwn-Davis-Besse ;:ending swee:ing revisions to emergency plans fcr the plant; and (2) a Cccciaint and Pecorandum cf Particulars in succor of that motion. We have included a nuc5er of documentary accendices i.n succort of our allegations whieft re Ecpe will facilitate NRC staff anessment and verification of our c:nclusicns. In light of the chacs that prevailed accng the public and state ~ emergency precaredness efficials curing the Three Mile Island crisis, it is in:erative tnat the NRC place increased stress upcn ecercency precarati:ns in the event cf nuclear accidents. To do less is'to ignore the threa: :: puolic health and safety whicn is posed by nuclear pcwer. With :ar-icular respect :: Cavis-Besse, :ne incredibly peer acera:Or and tacnnical per#ce.ance record Of die plan t.ndersc:res t. e need for t emergency plans to be revised and preven worta51e ncw, befena they might be recuired. Because of the imminent threat to health and safety wr:ich is pcsed by lax arrangements for emergencies at Davis-Besse,
- mereoy recuest that :ne NRC take all stecs to ex::edite TCSE's comoiaint.
If we cc nc have c:nfirmaticn of cefinitive action by the 'GC within fourteen (11) days of :nis date, we will be f:rced to examine the cotions of federal court facilitaticn. Henever, I am cer ain :na: the NRC is not willing to see the :nactic emergency pre:: ara-icns during tne TMI crisis receatad, and wili ad ct the same cim view of Davis-Besse emcrgency plans. :nat TCSE nas, and :nat :ne Cec =issicn aill act ~ quickly and res::ensibly. We asait your earliest prccessing of our c:mplain and request for restraining Orcer. Thank you for your :imely consideration. Rescectfully, .k... . ~, Terry-[. Locge,, g g ra s q Counsea or, i u. w N J a y y" ' Of J d:M
- r. Stecnen Burns, CELD t
u cc: ] 2 4 } () 4 7 Mr. Bruce Churchill, Counsei for Licensees t hhY
UNITED STATES OF AME.ICA 'qtr/to NUCLEAR REGULATCRY COMMISSICN 973 JLL 11 F,1 10 44 TOLED0 EDISON COMPANY AtlD ) DOCKET NO. 50-346 THE CLEVELATID ELECTRIC ILLUMINATING ) U E.c-CEL3 COMPANY ) ) MOTION FOR PRELIIIIt!ARY DAVIS-BESSE NUCLEAR POWER STATICtl, ) UNIT NO. 1 ) INJUUCTION ) Toledo Coalition for Safe Energy (TCSE), plaintiff herein, moves the U.S. Nuclear Regulatory Commission for a preliminary injunction, or suspension of power generating operations at Cavis-Besse Nuclear power Station, Unit No.1, with an injunction to Toledo Edison Company (TECo] and the Cleveland Electric Illuminating Company (CEI), their agents, servants, employees and attorneys and all pe.rsons in active concert and participation with them, pending a final determination of the need for and implementation of definitive corrective measures to Be taken upon the operating license issued to said respondents, from restarting Davis-Besse I on the grounds that (1) Unless restrained by this Comission, the rescondents will perform the acts referred to; (2) Such action by the respondents will result in exposing the plaintiffs hereto and other parties proximately situated to Davis-Besse to unnecessery and undue but substantial risks of irreparable losc, harm and damage to persons and property, as more particularly set forth in the verified comolaint of TCSE, attached to this f'otion; (3) The issuance of a preliminary injunction or order suspending operations at Davis-Besse by this Commission will not cause undue con-venience to respondents, or loss thereto, but will prevent irreparable injury to plaintiffs and other persons closely situated to Davis-Besse.a m pr
- ir lj lL
\\- 'O 3 7947 L3p 5.LS .= This Comission has the power to afford Complainants the relief sought herein. Further,10 CFR 52.206 et. sec. sets forth procedures for modification of an ope, rating license. By acting pursuant to these procedures, this Comission sits in place of the appropriate Federal District Court. 42 U.S.C. 92232 requires this Comission to ensure that nuclear operating licenses centain adequate conditions to " provide adequate protection to the health and safety of the public" (a). The injunc-tive relief sought herein is designed to afford this Cemission the reans to protect the public as required. Upon the verified Complaint herein, TCSE moves this Ccmission to issue a preliminary injunction or equivalent order of suspension of operations at Davis-Besse, as prayed for.in the Complaint and on the grounds therein set forth. 7/9/n
- lun, 01-
/ Terry 94 Locgen. Date e Counsel for the Toledo Coalition for~Sa'fe Energy d Served by me this day via certified mail upon Bruce Churchill, Counsel for TEco and CEI. j I} J f [. [, h.7 w Terr J Loage, 1243-049 S 6 E
UNITFD STATES OF AMERICA NUCLEAR REGULATCRY Cor.MISSICN ) TOLELO EDISCN COMPANY AND ) DOCKET NO. 50-346 THE CL.WELA :D ELECTEIC ILLUMINATING ) COMPANY ) COMPLAINT ) AND DAVIS-EESSE NUCLEAR PC'iEE STATICN, ) MEMCEA. CUM OF UNIT No. 1 ) PART:CULAE5- ) 1. Co=plainant Toledo Coalition for Safe Energy (TCSE) is a nonprofit corporation under the laws of Ohio, and is a coalition of customers of Toledo Edison Co=pany (TECo) with the co==on ai=s of pursuing saf ely-produced, equitably-priced energy, utilizing all legal devices of civil redress and action. Most of the =e=bership of TCSE lives within a twenty-five (25) =ile radius of Davis-Eesse Nuclear Power Station, Unit No. 1 (Davis-Besse), and stand to suffer ir-reparable personal injury, da= age and loss in the event of a serious accident at ravis-Besse. 2. The Davis-Eesse Nuclear Power Station is, fro = a generic design standpoint, closely related to the Babcock & '411cox nuclear reactor Three Mile Island II, near Harrisburg, Pennsylvania (TMI). In fact, because of defective design and personnel procedures which gave rise to the serious ac-cident at TMI on March 28, 1979, this Cor=ission ordered TEco and its co-licensee of Davis-Besse, Cleveland Electric Illu=inating Co=pany (CEI) to i=ple=ent certain design chan2es and personnel retraining prior start Davis-Eesse. This order DUPLICATE DOCUMENT 3 On April 24, 1979 TC Entire document previously entered into system under: James Keppler of NRC-Chicago of q gsyrg f ANO ] / / esUU - f 1.243 B50 No. of pages ____1.,,,...-,
,i,y o l OTTAlfA COU'i1Y RADIOLOGICAL E.\\5RGENCY PLA'1 .4.. 1243 051 -. #l I ' e q' \\ l pl f, ( (.. - \\ \\ [ ~~s ,3 [ \\ 3 s - 'i (, i *. g ,t e DUPLICATE DOCUMENT Entire document previously entered into system under: ANO e I i No. of pages: [ f ~
NUR EG-0396 EPA S20/178 016 PLANNING BASIS FOR THE DEVELOPMENT OF STATE AND LOCAL GOVERNMENT RADIOLOGICAL EMERGENCY RESPONSE PLANS IN SUPPORT OF LIGHT WATER NUCLEAR POWER PLANTS . A Report Prepared by a U. S. Nuclear Regulatory Commission and U. S. Environmental Pr.ctection Agency Task Force on Emergency Planning H. E. Collins *
- 8. K. Grimes **
Co Chairmen of Task Force F. Galpin *** Senior EPA Representative Manuscript Completed: November 1978 Date Published: December 1978 1243 052 ' Office at DUPLICATE DOCUMENT
- Office of Nuc!,
U. S. Nuclear Re Entire document previously Washingtc entered into system under: i
- Office of. f l
ANO Va in t No. of pages:
I. INTRODUCTIO!I Nuclear facility licensees are required by NRC regulations to develop emergency resronse plans (I) Portions of these regulations require the licensees to coordinate their plans with State and local agencies. Published Federal guidance recommends that State and local governments formalize their emergency response plans in support of these facilities to protect public health and safety in the unlikely ever.t of a significant release of radioactive material frem a nuclear facillty to the environment. Present Federal guidance
- suggests the use of a spectrum of accidents as a basis for developing emergency response plans.
For various reasons,* in 1976 an ad hoc Task Force of the Conference of (State) Radiation ControlPrcgramDirectorspassedaresoluhionrequestingNRCto"make a deteminaticn of the most severe accident basis for which radiological emergency response plans shculd be developed by offsite agencies". Additionally, the NRC and EPA 'eceived other comments frcm State and local governments relating to this reccmmendation.
- See Appenc1x II.
3 1243 054 Mismenee
, In November 1976, a Task Force consisting of 3RC and EPA represe was convened to aridress this Conference request and related issues. The Task Force reviewed what is currently being done in terms of emergency planning for newly ifcensed plants and found that substantial efforts were being made both in on-site and off-site planning.It also reviewed current guidance frcm Federal Agencies regarding e response planning (2,3,4 and concluded that adequate guidance was available or was being developed with regard to the elecents of a plan. While the previous guidance has not precisely specified distances to which planning elements should be appired, the actual current a'pplication of previous guidance on a case basis during the licensin process has in practice extended to, substantial distances frem reactor sites, i.e., independent cf pecific Lcw Population Zone distances used for siting purposes. However, information regarding the consequences and characteristics of the accident situation for which planning was being reccmmended had not been fully defined. The Task Force accepts the principle noted in existing NRC and EPA guidancef' that acceptable values for emergency doses to the public under the actual conditions of a nuclear accident cannot be predetermined. The emergency actions taken in any individual case 1243 054 must be based on the actual conditions that exist and are projected at tne time or an accident. For very serious accidents, predetermined protective actions would be taken if projected doses, at any place and time during an actua; accident, appe & ed to be at or above the appli-cable proposed Protective Action Guides (PAGs), based on information readily available in the reactor control rocm, i.e., at predetermined emergency action levels #) Of course, ad hoc actions, based on I plant or environmental measurements, could be taken at any 'ime. The concept of Protective Action Guides was introduced to radiologi-cal emergency response planning to assist ::ublic health and other ~ governmental authorities in deciding how much of a radiation hazard in the environment constitutes a basis for initiating emergency protective actions. These guides (PAGs) are expressed in units of radiation dose (rem) and represent trigger or initiation levels, which warrant ;re-selected protective actions for the public if the projected (future) dose received by an individual in the absence of a protective action exceeds the PAG. PAGs are defined or definable for all pathways of radiation exposure to man and are proposed as gt.idance to be used as a basis for taking action to minimize the impact on 1.1dividuals. 1243 055 O '4
. The nature of PAGs is such that they canact be used to as a given level pf exposure to individuals in che population is prevented. In any particular response situation, a range of doses may be experienced, principally depending on the dist frem the point of release. Scme of these doses may be well in excess of the PAG levels and clearly war ' ant the initiation of any feasible protective actions. This does not mean, however, that doses above PAG 1evels can be prevented or that eme response plans should have as their objective preventing doses above PAG levels. Furthermore, PA(b represent only trigger levels and are not intended to represent acceptable dose levels. PAGs are tools to be used as a decision,ld in the actual response situat hetheds for the implementation of Protective Action Guides ar essential element of emergency planning. These incicde the pre-determination of emergency conditions gor which planned pro actions such as shelter and/or evacuation would be impiecented offsite. Details of these metheds are being provided as separate guidance (3,4) and ara not included in this' report. _ Accident Considerations After considerable discussion, the Task Force concluded that th was no specific accident sequence that could be isolated as the one for which to plan, because each accident could have different
- +- Goes-consequences, both in nature and degree.
Furcher, the range of possible selections for' a planning basis is very large, starting with a zero point of requiring no planning at all because signifi-cant offsite radiological accident consequences are unlikely to occur, to planning for the worst physically possible accident regardless of its extremely low likelihood. As an alternative to attempting to define a specific accident sequence, the Task Force decided to identify the bounds of the parameters for which planning is recommended based upon a knowledge of the potential consequences, timing, and release characteristics of a spectrum of accidents. The Task Force rec 0gnized that more specific guidance with respect to accidents whose consequences wculd be more severe than the design basis accidents explicitly considered in the licensing prccess was appropriate. Additional discussions regarding the need to plan for consequences of such accidents (ccmtr.cnly known as Class 9 accidents *) may be found in Appendix III. The Task Force concluded that the cbjective of emergency response plans should be to provide dosa savings for a spectrum of accidents that could produce offsite doses in excess of the PAGs. Although the selected "Inrougnouc tnis reocrt, " Class 9 accidents" will refer to those accidents in which there is melting of the core and/dr containment failure. 124 057 ~
Q; Gk f tb ta\\ z
- G a w n '.
planning basis is independent of a specific accident sequence, a nu of accident descriotions were reviewed including the design basis acc with various active engineered safety features, and the accident rele categories of the Reactor Safety Study
- Additional information regarding the rationale for the reccmme basis,the background of Federal emergency planning efforts, the T deliberations on Class 9 accidents, the relationship between eme planning and siting criteria, and the difference between PAGs and d criteria used for siting can be found in the appendices to this report.
2 i Ine Task Force nas used information in the RSS as a basis to perform calculations wnich illustrate the likelihood of certain offsite levels given a core melt accident. Varicus ascects of the stucy have been debated by reviewers ano additional orograms are underway t or refine the study. While the RSS is considered oy the Task Force to have limited use in dealing with clant/ site specific factors, it provide the best currently availaole scurce of information en the relative likelihooc of large accicental releases of radioactivity given a core melt event. The results cerived fecm tne RSS-based' work served to distance around nuclear power plants is prudent and ~' vw II. PLANNING NEEDS The Task Force reviewed t e types of infomation that State and local governments need to develop emergency response plans and determined that the infomation fell into two categories; site specific and generic. The site specific information such as ~ population distribution and topography must be available to State and local officials as part of the planning process. Such informa-tion is summarized in Environmental Reports and Safety Analysis Reports prepared by applicants for a pemit to construct and operate a nuclear pcwer facility and is useful for emergency planning purposes. Some generic information related to the planning effort is already being provided by Federal agencies (2' ' The Federal generic guidance provided includes the topics which should be addressed in an emergency plan ( ' , protective action guides the types of protective action aopropriate(3) and emergency instru-mentation considerations (,6,71 If it were possible to identify a single accident on which to base emergency response planning, one could use the release' characteristics of that single accident in connection with site specific characteristics and other generic infomation to specify the planning effort. Having detemined that a single specific accident secuence for a light water 1243 059
Q l4 0 nn19 %,g n Qu'1 W a q N ~ ~ >J g indU reactor nuclear pcwer plant cannot be identified as a planning basis, the Task Force chose to provide recommendations in tems.of the con quences or c$aractaristics of accidents that would be impo determining the extent of the planning effort. The planning basis elements needed to scope the planning effort were determined to be: 1. The distance to which planning for the. initiation of predetermined protective actions is warranted. 2. The time dependent characteristics of potential releases and exposures. 3. The kinds of radioactive materials that can potentially be released to the environment. The most important guidance for planning officials is the distance -t. from the nuclear facility which defines the area over which plannin for predetermined actions should be carried cut. The other elements . of guidance provide supporting information for planning and preparec The need for specification of distance for the major exposure pathways is evident. The location of the population for whom actions may be needed, responsible authorities who would carry out these actions and t e means of ccmmunication to these authorities dependent on the size of the planning area. 1243 060 e h 6** hm Information on the time, frames of the accidents is also important. The time between the initial recognition at the nuclear facility that a serious accident is in progress and the beginning of the radioactive release to the surrounding environment is critical in determining the type of protective actions which are feasible immediately folicwing an accident. Likewise, knowledge of the potential duration of release and the time available before exposures are expected several miles offsite is important in deterniding what specific instructions can be given to the public. A knowledge of kinds of radioactive materials potentially released is necessary to decide the characteristi s of monitoring instru-mentation, to develop tools for estimating projected doses, and to identify the most important exposure pathways. In this report, emergency preparedness is related to two predcminant exposure pathways. They are: l. Plume excosure cathway -- The principal exposure sources frca this pathway are (a) whole body external exposure to gamma radiation frem the plume and frca deposited material and (b) inhalation exposure frem the passing radioactive plume. ~ The time of potential exposure could range frcm hours to days. 1243 06i 2. Ingestion excosure cathway -- The principal exposure frem this pathway would be frca ingestion of contaminated water or foods such as milk or fresh vegetables. The time of potential exposure could range in length frca hours to montns. The Task Force has provided separate guidance for these two exposure pathways, although a single emergency plan would include elements common to assessing or taking protective actions for both pathways. I 't 6 6 M 9 e
11 - III. REC 0fdtdENDED PLArtilING BASIS A. jmergency Planning Zohes With re ard to the area over which planning efforts should be w carried out, the 'Isk Force reccmmends that " Emergency Planning Zones" (EPZs) about each nuclear facility be defined both for the short term " plume exposure pathway" and for the longer term " ingestion exposure pathways." The Emergency Planning Zone concept is illustrated in figure 1. EPZs are designated as the areas for which planning is recccmended to assure that prcmpt and effective actions can be taken to protect the public in the event of an accident. Responsible government officials should apply the applicable planning items fi ted in NUREG-75/111(2) in the develocment of radiological emergency response plans. The folicwing are example planning elements considered appro-priate for the E?Zs: ~ (1) Identify resconsible onsite and offsite emergency response organizations and the mechanisms for activating their
- services, (2)
Establish effective cccmunication networks to prcmptly notify ~ cognizant authorities and the public, (3) Designate pre-determined actions as apprcpriate(2,3,4) 1243 063 e
hY R ET N YE nC l N A G E O N S I LI S g T oS S EE C T E pA MV E gE U An C R LRi to PTD n A e M
- lEOss
} \\ \\ f 3 f S \\ ~ o k 'i Z j u h_ \\ in n n } k a N l d P y Y c N h,\\ E n egr h e m \\ \\ h e t tpec N n / o }Il C 1 N e A- \\ r A s uA N, x3 E u nt q nl ; R g 4 / ?. N N Z) P L E ( N-E ~ O N 'I Z o e G z O N - )E n A,.V I - U gg g. o I g l g oi g A h tg d A E g i L ,o e .hn R g A u y NO ,d ls \\ u 5 l p/ C i p X p E g v C C' :>. D 4 [3 (4) Develoo procedures for use by emergency workers, (5) Identifyacclicabferadiationmeasurementequipment, (6)' Identify emergency operations centers and alternate locations, assembly points, and radiation monitoring locations, (7) Imolement training programs for emergency workers as appropriate, and (8) Develoc test procedures for emergency response olans. Emergency planning should predetermine appropriate emergency responses within the EPZ as a function of population groups, environmental conditions , plant conditions ) and time N) available to respond. For the plume exposure phase, shelter and/or evacuation would likely be the principal immediate protective actions to be recccmended for the general public within the EPZ. The aoility to best reduce exposure should determine the appropriate response. The key to effective planning is good communication to authorities who know what they are going to do under pre-detemined conditions. For the ingestion exposure Emergency Planning Zone, the planning effort involves the identification of major exposure pathways frcm contaminated focd and water and the associated 1243 065 control points and mechanisms. The ingestion pathway ext.osures in general wouid represent a longer term problem, although some early protective actions to minimize subsequent contamination of milk or other supplies should be initiated (e.g., put cows on stored feed). It is expected that judgment of the planner will be used in detemining the precise size and shape of the EPZs considering local canditions such as demography, topography and land use characteristics, access routes, jurisdictional boundaries, and arrangements with the nuclear facility coerator for notification and response assistance. The EPZ guidance does not change the requirements for emergency planning, it only sets bounds on the planning problem. The Task Force does not recernend that massive emergency preparedness pregrar.s be established around all nuclear pcwer stations. The fo11cwing examples are given to further clarify the Task Force guidance on EPZs$ No soecial local decontamination provisions for the general public (e.g., blankets, changes of clothing, food, special showers) No stockoiles of anti-contamination equipment for the general public No construction of specially equipped fallout shel'.ers 1245 066 No saecici radiological medical prov,, ions for the general public No new construction of spe'cial public facilities for emergency use No soecial stockpiles of emergency animal feed No soecial decontamination equipment for property and equipment No carticication by the general public in test exercises of emergency plans. Some capabilities in these areas, of course, already exist under the general emercency plans of Federal and State agencies. B. Size of the Emergency Planning Zone Several possible rationales were consider'd for establishing the e size of the EpZs. These included risk, prcbability, cost effectiveness and accident consequence spectrum. After reviewing these alternatives, the Task Force chose to base *he rationale on a full spectrum of accidents and corresponding consequence < tempered by prcbability considerations. These rationales are discussed more fully in Appendix I. The Task Force agreed that emergency response plans should'be useful for responding to any accident that would produce offsite doses in~ excess of the PAGs. This would include the more severe design basis accidents and the accidelt spectrum analy:ed in the RSS. After reviewing the potential consequences associated with i243 067
ki ~ ~ these types of accidents, it was the concensus of the Task Force that emer ency plans could be based upon a generic distance out to which predetermined ac'tions would provide dose savings for any such accidents. Beyond this oeneric distance it was concluded thi actions could be taken on an ad hoc basis using the same considerr.. that went into the initial action determinations. The Task Force judcment on the extent of the Emergency Planning is derived from the characteristics of design basis and Class 9 accident consequences. Based on the information provided in Appen: I and the applicable PAGs a radius of about 10 miles was selected for the plume exposure path ay and a radius of about 50 miles was selected for the ingastion exposure path ay, as shown in table 1. Although the radius for the EP7. implies a circular area, the actua: shape would depend upon the characteristics of a particular site. The circular or other defiaed area wculd be for planning whereas initial response would likely 11 nlve only a portion of the totai a-The EPZ reccmmended is of sufficient size to provide dose savin the population in areas where the projected dose frca design basis accidents ccuid be expected to exceed the applicable PAGs under unfavorabic atmosphe.-ic conditions. As illustrated in Appendix I, consequences of less severe Class 9 accidents would not exceed the 3743 068 PAG levels outside the recccmended EPZ distance. In addition, the EPZ is of sufficient size to provide for substantial reduction in early severe health effects (injuries or deaths) in the event of the more severe Class 9 accidents. Table 1. Guidance on Size of the Emergency Planning Zone Critical Organ and Accident Phase Exposure Pathway LPZ Radius Plume Exposure Whole body (external) about 10 mile radius * - Pathway Thyroid (inhala'Eion) Other organs (inhalation) Ingestion Pathway ** Thyroid, whole body, about 50 mile radius *** bone marrow (ingestion) Judgmen't should be used in adopting this distance based upon considerations of local conditions such as demograchy, topograchy, land characteristics, access routes, and local juriscictional Ocundaries.
- Processing plants for milk produced within the EPZ should be included in the r.tergency response plans regardless of their location.
- The reccmmended size of the ingestion exposure EPZ is based on an ex ected revision of milk cathway Protective Action Guides based on FDA-Bureau of Radiological Health recommendations. The Task Force understands that measures such as placing dairy ccws on stored feed will be reccmmended for projected excesure levels as low as about 1.5 ran)to the infantShou thyroid.
- Processing plants for milk produced within the EPZ should be included in the r.tergency response plans regardless of their location.
an-EPZ of about 25 miles would achieve the objectives of the Task Force. 1243 069
18 - C. Time Factors Associated with Releases The planning ; time frames are based on design basis accident consideratians and the results of calculatitns reported' in 3e- ." ['i* Reactor Safety Study The guidance cannot be very specific .s
- . l.!;.'p i. il because of the wide range of time frames associated with the yG%
.9. - ; m.r. .[.., l i H.. o: .-M spectrum of accidents considered. Therefore, it will be ilij ly q .'g 9' T, necessary for planners to consider the possible different y lh hd;.1
- j
' f L ll,w A,9 time periods between the initiating event ar.d arrival of the n%~ piq pi ;. myn plume and possible time periods of releases in relationship to e 3 l h-i. .3 lj Hi time needed to implement protective actions. The Reactor Safety
- f jh Study indicates, for example, that major releases may begin in the 3
phji K lhPm P:: range of one-half hour to as iuch as 30 hours after an initiating 3 lU. f,n'- -event and that the duration of the releases may range frem cne-e t ipn 3,.
- y; j lhl.y 3
i f l dl :'n"j half hour to several days with the major portion of the release lt, u:1 'I l i fl.d 1 occurring well within the first day. In addition, significant plume .a i..o m 4
- i. ; y, ci
, [l li.." travel times are associated with the most adverse metecrological im' t-c. ,' hih.j conditions that might result in large potential exposures far .~ ..,g. E g (,". from the site. For example, under poor' dispersion conditions 4 i*,i-i g lp;.;g8.y. associated with icw windspeeds, two hours or acre might be required y h t;p.. for the plume to travel a distance of five miles. Higher wind- .,i u !;h '" speeds wculd result in shorter travel times but would provide
- I
.p' more dispersion, making high exposures at long distances much less likely. Therefore, in most cases, significant advance warning 1243 070 I
- ~ %. A. _. _
of high concentrations shculd be available since NRC regulations ( ' ) i require early notification or offsite authorities for major releases of radioactive material. The warning time could be somewhat different for reactors with different containment characteristics than those analyzed in the Reactor Safety Study. The range of times, however, is judged suitably representative for the purpose of developing emergency plans. Shorter release initiation times are typically associated with design basis events of much smaller potential consequences or with the more severe Reactor Safety Study accident sequences. t The planning basis for the time depender$e of a release is expressed as a range of time values in which to implement protective action. This range of values prior to the start of a major release is of the order of one-half hour to several h.ours. The subsequent time period over which radioactive material may be expected to be released is of the order of one-half hour (short-term release) to a few days (continuous releast). Table 2 summarizes the Task' Force guidance on the time of the release. The time availa'ble for action is strongly related to the time consumed in notification that conditions exist that could cause a major release or that a major release is occurring. Deveioccent and periodic testing of procedures for rapid notification are encouraged. 1243 071
' s, 20 - 's ~ x 'N Table 2 - Guidance on Initiit-ion and Duration of Release I Time.frem the initiating event 0.5 hours to one day to start of atmospheric release Time period over which radioactive 0.5 hours to several days material may be continuously released Time at which major portion of 0.5 hours to 1 day after release may occur start of release Travel time for release to exposure point 5 miles - - 0.5 to 2 heure (time after release) 10 miles - - 1 to 4 hours D. Radioloaical Characteristics of Releases To specify the characteristics of monitoring instrumentation,* develop decisional aids to estimate projected doses, and identify critical exposure modes, plarners will need information on the characteristics of potential radioactivity releases. For atmospheric releases frca nuclear power facilities, three dominant exposure =cdes have been identified. These are (1) whole body (bone.marrcw) exposure from external gamma radiation and frca ingestion of radioactive material; (2) thyroid exposure frem inhalation or ingestion of radiodines; and
- An Interagency Task, Force on Emergency Instrumentation (offsite) is new preparing goidancev') on the tyce and quantity of instruments needed for the various cx:osure pathways.
Federal agencies represented on the Instrumentation Task Force include NRC, E?A, DCPA, HE'd, and 00E. 1z43 072 ^ -r
(3) exposure of other organs (e.g., lung) frem inhalation or ingestion of radioactive materials. Any of these exposure modes could dominate (i.e., result in the largest exposures) depending upon the relative quantities of various isotopes released. Radioactive materials produced in the operation of nuclear reactors include fission products and transuranics generated within the fuel material itself and activation products generated by neutron exposure of the structural and other materials within and immediately around the reactor core. The fission products consist of a very large number of different kinds of isotopes (nuclides), almost all of which are initially radioactive. Th. amounts of these fission products and their potential for escape frem their normal places of confinement represent the dcminant potential for consequences to the public. Radioactive fission prcducts exist in a variety of physical and chemical forms of varied volatility. Virtually all activation products and transuranics exist as non-volatile solids. The characteristics of these materials shows quite clearly that the potential for re: eases to the environment decreases dramatically in-this order:- (1) gaseous materials; (2) volatile solids; and (3) non-volatile solids. For this reason, guidance for source ter ns representing hypothetical fission product activity within )O i ~) ~ a nuclear power plant containment structure emphasizes the development of plans relating to the release of noble gases and of volatiles such as fodine. How ver, consideration of particulate materials should not be completely neglected. For example, capability to determine the presence or absence of key particulate radionuclides will be needed to identify requirements for additional resources. Table 3 provides a list of key radionuclides that might be expected to be dominant for each exposure pathway. More detailed lists,of core inventories are presented in Chapter 15 of recent Safety Analysis Reports and in Appendix V of the Reactor Safety Study. Both of these sources give details on the time histories of the release fractions for a spectrum of postulated acc.1 dents. } e 1243 074 e N
- s 6
e ~ ~
Table 3 RADIONUCLIDES WITil SIGNIFICANT CONTRIBUTION TO DOMINANT EXPOSURE MODES Radionuclides with Significant Contribution to lung Exposure * (Lung only controlling when thyroid dose is reduced by lodine Radionuclides with Significant Radionuclides with Significant blocking or there is a long delay Contribution to Thyroid Exposure Contribution to Whole Body Exposure prior to releasesh _ lla) f Life llal f Li fe llalf Life j iay i Radionuclide __(days) Radionuclide (day i Radionuclide l I-131 8.05 I-131 8.05 1-1 31 0.05 1-132 0.0858 Te-132 3.25 1-132 0.0858 1-133 0.875 Xe-133 5.28 I-133 ' O.875 I-134 0.0366 I-133 0.875 I-134 0.0366 I-135 .028 Xe-135 0,384 I-135 .028 Te-132 3.25 I-135 .028 Cs-134 750 03 Kr-88 0.117 Cs-134 '750 Kr-88 0.117 Kr-88 [- 0.117 Cs-137 11,000 Cs-137 11,000 Ru-106 365 N Te-132 3.25 [ Ce-144 284 O N tn
- Derived from the more probable Reactor Safety Study fuel melt categories and from postulated design basis accident releases.
1 4 IV. _ CONC 1.USIONS 4 In summary, the Task Force concludes that: . A spectrum of accidents (not the source term frcm a accident sequence) shculd be considered in developing basis for emergency planning. . The establishment of Emergency Planning Zones of ab miles for the plume exposure pathway and about 50 mi the ingestion pathway is sufficient to scope the areas i n which planning for the initiation of predetermined prot action is warranted for any given nuclear pcwer plant . The establishment of time fr mes and radiological of releases provides supporting information for plann preparedness. . If previous consideration has been given to the ba elements put forth. in existing guidance dccuments( ' '#) the establishment of Emergency Planning Zones should n result in large incremental increases in required plann and preparedness resources. gA3 076 me
DN p Pd "* 3 ,- "hf6 dNk%3ik 25 - 1 REFERENCES 1. 10 CFR Part 50, Licensinc cf Production and Utilization Facility, Accencix i, u. 5. Nuclear Regulatory Cc mission, Wasnington, D. C. 2. Guide and Check List for the Develecment and Evaluaticn of State and Locai Gcvernment.acicicgicai imergency Rescanse lans in Succort of Fixec iiuciear Faci 1 les. NUREG-75/ lli, Dec. i974, U.S. iiuclear Regulatory Ccmmission. 3. Manual of Protective Action Guides and Protective Actions for Nu c l e a.- Inc1 cents, d A-522/ i -7 5-G01, Sept. t975, U.S. Envirent: ental Protection Agency. 4. Emercency Planninc for Nuclear Power Plants. Reculatory Guide 1.101, har. 1977. U.S. suclear Regulatory CcmmissTon,' Washington, D. C. ~ 5. Reactor Safety Studv: An Assessment of Accident Risks in U.S. Commerciai Nuclear Power diants. (NUREG-75/014. Cctccer 1975. WASH-1400, U.S. Nuclear Reguiatcry Cctr:11i s s i on. 6. Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant Concitions Curing anc foilcwinc an Acc1 cent, Regulatory Guice 1.97, Dec. 1975, U.S. Nuclear Regulatory,.Cc= mission, Washington, D. C. ~ 7. Interim Guidance on Offsite Raciaticn Measurement Systems, A Report to Developers or 5 tate Rac1oicgical Emergency Res::cnse Plans by the Federal Interagency Task Force on (offsite) Emergency Instrumentation for Nuclear Incidents at Fixed Facilities, August 1977, U.S. Nuclear Regulatcry Commission, Washington, D. C. 8. Federal Radiaticn Ccuncil Staff Recort No. 5, July 1964; Staff Report No. 7, May 1965. 9. Federal Resconse Plan for Peacetime Nuclear Emergencies (Interim Guidance' Aprli 1977, Federal Preparecness Agency, General Services Acministraticn. 10. Disaster 0::erations. A Handbcok for Local Governments (CPG l-6) July 1972, & Cnange ao. i, June 1974, Defense civil Preparecness Agency. 11. Radiolacical Incident Emercency Rescense Planninc. Fixed Facilities and ~ Transcortation: interacency xescensic1 t i ti es,.-ecera i Pre::arecness Agency General 5ervices Ac=1nistration, feceral Register Notice, Vol. 4U, No. 248 December 24, 1975. 1243 077 GLOSSARY I Class 9 Accident An accident considered to be so low in probability as not to require specific additional provisions in the design of a reactor facility. Such accidents wc-f' C
- . k
,f more severe than those postulated for the purpose of establishing the design basis for protective systems and engiras-safety features. (Class 9 event secce :i include those leading to total core me:: ' nd consequent degradation of the conta - ment boundary and those leading to gr::: fuel clad failure or partial melt with independent -failures of the containmer.: boundary). Consecuences The results or effects (especially pr:f t: dose rates) of a release of radioactiva material to the environment. Core Melt Accident A postulated reactor accident in which :- fuel melts because of overheating. 1243 078 P Emergency Plannino Zone (EPZ) A generic area defined abcut a nuclear i facility to facilitate emergency planning offsite. It is defined for the plume and ingestien expcsure pathways. In relation to energency response an E?Z is an area in ~ which best effort is performed making use of existing emergency plans and is not an area in which particular criteria must be met. o thway The principal expcsure frcm this pathway Ingestion Execsure a wouldbefread,ingestionofcontaminated water or foods such as milk or fresh vegetables. The time of potential exposure could range in length frcm hours to conths. Planning Basis Guidance in terms of (1) Size of Planning ~ Area (Distance); (2) Time Dependence of Release; and (3) Radiological Characteristics of Releases. 1243 079 -ome.. Plume Excosure Pathway The principal exposure sources fran this pathway are: (a) whole bcdy external I exposure to gamma radiation frcm the plume and frcm deposited materials and (b) inhalation exposure frem the passing radioactive plume. The time of potential exposure could range in length frem hours to days. Projected Dose An estimate of the radiation dose which affected population grcups cculd potentially receive if protective actions are not taken. Protective Action An a ion taken to avoid or reduce a projected dose. (Sometimes referred to as protective measure). Protective Action Guide Projected absorbed dose to individuals in the general population which warrants protective action folicwing a contaminating event. Source Term' Radioisotope inventory of the reactor core, - or radioisotope release to the environmenc, often as a function of time. 1243 080 M ena e G ge
APPENDIX I RATIONALE FOR THE PLANNING EASIS General Considerations A. The Task Force considered various rationales for establishing a planning basis; including risk, probability, cost effectiveness, and consequence spectrum. After studying the various approaches discussed below, the Task Force chose to base the rationale for the planning basis 1 on a spectrum of consequences, tempered by probability consider-ations. With respect to the risk
- rationale,such an approach would establish " planning guidance" thatI could be compared with This the risks associated with non-nuclear accidents.
rationale would seemingly give a uniform basis for emergency planning and would clearly indicate the level of risk that could be mitigated by advanced planning. Hcwever, emercency planning for non-nuclear hazards is not based upon quantified risk analyses. Risk is not generally thought of in terms of probabilities and consequences, rather it is an intuitive feeling of the threat posed to the public. Reactors are unique in -this ~ I regard: radiation tends to be perceived as more dangerous than other hazards because the nature of radiation effects are les: ccmmonly
- Risk is defined as accident consequences times the probability of accident occurrence.
1243 08i
I-2 ~ understood and the public generally associates radiation effects with the fear of nuclear weapons effects. In additicr a riskbrelated rationale mignt i cly the determination of an acceptable level of risk which is outside the scope of the Tas Force effort. Chcosinc a risk comcarable to ncn-nuclear ever:- therefore, was not directly used as the rationala for an ecer: planning basis. 5, 9i With respect to a probability rationale, one could arrive at " planning guidance" by selecting an accident probability below which developmen,t of an emergency plan could not be 1. justified. Factors favoring using this rationale center ar:-.- providing a cuantitative probability basis, which could be compared with the probabilities of other types of emergencis for which plans are prepared. Factors arguing against the probability rationale are similar to those against the risk approach. F.mergency planning is --- based upon quantified probabilities of incidents or accidents. the basis of the accident crobabilicies presented in the 0.er.:: k fety Study (nuclear and non-nuclear) society tolerates muc-probable non-nuclear events with similar consecuence s ectr. : without any scecific planning. Radiolcgical emergency ol an.n" not based upon probabilities, but on oublic ::erception:, of :. _ prcblem and what could be dene to protect health and saferv. essence, it is a matter of crudence rather than necessi ty. 1243 082
I-3 = i Ageneric " probability of an event" appropriate fue piancing has many implications felt to be outside the scoce of the Task Force ob.ie cti ve. H wever, the ccaceot of accident probability is imoortan; and does have a clace in terms of evaluatinc the rance of the consequences of accident sequences and setting scme reasonable bounds on the planning basis. The probability rationale was used by the Task Force to gain additional perspective on the planning basis finally chosen. With respect to a cost-effectiveness rationale, the level of emergency planning eff_et would be based on an analysis of what it costs to develop different levels of such a plan and the potential consequences th'a could be averted by that degree of development. The factor favcring the cost-effectiveness rationale is that an emergency plan could be developed on the basis of cost per potential health effect averted. Factors arguing against the cost-effectiveness rat;cnale are the dif-ficulty in arriving at costs of plan development and maintenancs and considerations that general and radiological emergency response plans have already bee, developed. In addition, absent an a.ctual accident, it would be very difficult to assign a dollar value to the effectiveness of the plan in terms of health efte.t: averted. Lastly, the calculated consecuences from a spectrum of postulated accidents was considered as the rationale for the planning basis. i 1243 083 l O
I-4 Such a rationale could be used to help identify desirable planning elements and establish bounds on the planning effort. Further, a planning basis could be easily stated and unders :: in tems of the areas or distances, time frames and radio-logical characteristics that would correspond to the conse-f ,dfla .} a guidance would also provide a consistency and uniformity in the amount of planning recommendec to State and' local governments. The Task Force therefore judged that the consa-quences of a si.sctrum of accidents shculd be the principal rationale behind the planning basis. B. Consecuence Considera ions The Task Force considered the ccmplete spectrum of accidents postulated for various purposes, including thosa discussed in environmental reports (i.e. best estimate Class 1 througr 8 accidents), accidents postulated for purposes of evaluati ; plant designs (e.g. the DBA/LCCA), and the spectrum of accidents assessed by the Reactor Safety Study. The Task :or: concluded that the environmental report discuse, ions (Class 1-! were too limitea in scope and detail to be useful in emerg=nc. planning. 1. Desien Basis Accidents Under NRC Regulations, the si':3/ reactor design combination u be such that the consequences of desigt. basis accidents are 12 0 084
I-5 below the plume exposure guidelines of 10 CFR Part 100. The a design basis loss-of-coolant accident (DSA-LCCA) has been i typically the most severe design basis accident in that it results in the largest calculated offs.it;e doses of any accident in this class. The DBA-LOCA is not a realistic accident scenario in that the release magnitudes are much more severe than would be realistically expected and may exceed that of scme core-melt type accidents. A test estim:te assessment of the release following a LOCA would be significantly smaller than the DSA-LCCA used for siting purposes. An analysis of this accident has been performed for most of the power plants licensed or under review by NRC to determine the dose /digtance relationships as ccmputed ~5 by traditionally conservative assumptions used under 10 CFR Part ' 100 requirements. Results of this study are presented later in this appendix. The study concluded that the higher PAG plume exposures of X rem (thyroid) and 5 rem (whole body) would not be exceeded beyond 10 miles for any site analyzed. Even-under the most restrictive PAG plume exposure values of 5 rem to the thyroid and 1 rem whole body, over 70 percent of the plants would not require any consideration of emergency responses beyond 10 miles. It should be noted that even for the DBA-LOCA, the lower I range of the plume PAGs would likely not be exceeded outside the l I low population :cne (L?Z) for average meteorological conditions. 1243 085
I-6 For the ingestion pathways, under the same DBA-LCCA conditicr.s. the downwind ange within which a PAG of 1.5 rem thyroid c:ul: be exceeded would be limited to within 50 miles even under the conservative 10 CFR 100 assumptions. The 50 mile distance is also justified as a maximum planning distance because of likely significant wind shifts within this distance that would further restrict the radius of the spread of radica: material. ,'%"'Nhd 8 P ua 2. Class 9 Accidents " Class 9" accidents cover a full spectrum of releases wnich cl.- from those accidents wnich are of the same order as the DBA-L:: type of releases; f.e.,. doses on the order of PAGs within 10 -- to those accidents which release significant fractions of the available radioactive materials in the reactor to the atmos:hir-thus having potential for life-threatening doses. The icwer range of the spectrum wculd include accidents in which a core " melt-through" of the containment would occur. As in the 05A.. class, the doses from " melt-tnrough" releases (involving ' thousands of curies) generally would not exceed even the mos restrictive PAG beyond about 10 miles frem a power plant. The upper range of the core-melt accidents is catescrized by these in which the contair. ment catastrophically fails and releases :1 quantities of radioactive materials directly to the atmosphe. e because of over-pressurization or a : team explosion. These 1243_086
I-7 accidents have the potential to release very large quantities (hund. :$s of millions of curies) of radioactive :aterials. There is a full spectrum of releases between the icwer and upper range with all of these releases involving scme ccmbination of at.ospheric and melt-through accidents. These very severe accidents have the potential for causing serious injuries and deaths. Therefore, emergency response for nese concitions must nave as its first priority the reduction of early severe nealtn effects. 5tuaies(O' } have been performed wnien incicate tnat if emergency actions sucn as sheltering or evacuation were taken witnin acout lu miles of a power plant, there would be significant savings of early injuries ano oeatns frem even tne most " severe" atmospneric releases. 3 For the ingestion pathways, (due to the airborne releases and under Class 9 accident conditions), the downwind range within which significant c:ntamination could occur would generally be limited to about 50 miles frcm a power plant, because of wind shifts during the release ard travel periods. There may also be conversion of iodine in the atmosphere (for long time periods) to chemical forms which do not readily enter the ingestion pathway. Additionally, much of the particulate materials in a cloud would have been deposited on the ground within about 50 miles. C. Probability Considerations An additional perspective can be gained when the planning basis is considered in terms of the likelihood (probability) of l accidents which could require some emergency response. 1243 087
I-8 Pro'babilities can be used to give a perspective to tne emergency planner by ccmparing the chance of a reactor accica.- to other emergencies,for which plans and action may be requir: This consideration foms an additional basis upon which the Task Force selected the planning basis. The Reactor Safety Study (RSS) estimated the probabilities
- of various severe accidents occurring at nuclear power plants.
The orobability : M FIN a loss-of-coolant accident (LOCA) fr:m a large pipe break was dud Mili likeT, estimated to be approximately one chance in 10,0C0 (1x10 ) of occurring per reactor-year. LOCA accidents would not necessar-lead to the melting of the reactor core since emergency core cooling systems (ECCS) are designed to protect the core in such an event. In fac[ other accident initiating events suc.- as the loss-of-coolant accident frca a small pipe break or transient events have a higher chance of leading to core-mel:i-than do large LOCA accidents. Core-melt type accidents were ~ calculated to have a probability of about one chance in 20,0C-of occurring per reactor-year. There is a significant degree of uncertainty associated with both of the above probability estimates.
- Use of the RSS probability estimates, in the context of emergency planni--
has been thorougnly examined. of uncertainties in these numcers (as indicat$d in the Risk Assess Review Grcuo Recort,."UREG/CR-Oa00), but the perspective gained wnen c:n-sidering tne procacilities is important in making a rational decision concerning a basis for emergency planning. 1243 088 -o
I-9 The degree of uncertainty is such that no differentiation can be confidently made, en a probabilistic basis, between the DBA/LOCA and the' releases associ ted with less severe core-melt categories. As discussed in Appendix III, the Task Force has concluoed that both the design basis accidents and less severe core-melt accidents should be considered when selecting a basis for planning pre-detennined protective actions.and that certain features of the more severe care-melt accidents should be considered in planning to assure that some capability exists to reduce the censequer:ces of even the most severe accidents'. The low probabilities associate'd with core-melt reactor accidentf(e.g. one chance in 20,0C0 or 5 x 10-5 per reac or-year) are not easy to ccmprehend and additional perspectives are useful. Within the ne.it few years, there will have been accumulated approximately 500 reactor-years of civilian nuclear pcwer plant operation in this country. Less the 10% of all core melt accidents would result in high exposure outside the recommended planning distances. Therefore, over this time period
- the probability of an accident within the USA with exposures exceeding the plume or ingestion PAGs outside the planning basis
~c, distances would be about 15 x 10 ~ x 500 or about 1 chance in The Reactor Safety Study explicitly limits its analyses to the first 100 reactors and five years (through 1980). ?'
- This estimate is based upon the assumptions of the RSS.
It should l be noted that there is a large uncertainty on this number. 1243 089 _e.. e e
}> 100. To restate this, there is abcut a 1% chance of emerger.:. plans being activated in the U.S. beyond the recommended E? D within the next few years. For a single State, this probabi' drops appreciably. For a State with ten reactors within or j.i ' adjacent to its borders, the orobability of exceeding PAGs ..i
- l!2. [Ij!:),
outside the planning basis radius for the plume exposure pa.- p d.i :'; -5 M l is about 1.5 x 10 x 10 or about one chance in 6000 per year 9 jj,, ji[. according to the Peactor Safety Study analysis. 3 . no., : e-l.
- t ;sa l, "
' I t i. :: j,vi For perspective, a comparison between reactor accidents ar.d u J pi l 11 m!..!, ' ih!I,iji other emergency situations can be made. Considerations of D f g;1 Vil .,!h ::' N;:l emergency planning for reactor accidents are quite similar i
- k..
!t [l g 'l,j! to many other emergencies; floods, for example, have many j[. ; f,n !.; M ::js, p:,12 characteristics which are comparable. Timing, response .u w ;., h..:[ :gj measures and potential consequences, such as property , j!:li;' :. ; j '! ' j. h' F 'di.H ' damage are similar for both events. j@f
- pi.. !.%;hl jI; ff., i,[,q Flood risk analysis has been carried cut by the Flood h{j!yi -h'j
,J. j Insurance Program of the Department of Housing and Urban c..,,v.. .Wi i!. Development and the Corps of Engineers. Flood plains have r 1, e i.. h]"{t'?. 1 r ; 1 ,i: g, been designated for all areas of the country by computing ..f;r ll the probability of being flooded within a certain period 3. .i of time; ie., the 100-year flood plain designates those areas which can be expected to be under water when the wors-flood in a century occurs. Even with this relatively high probability of severe ficod accurrence there are no explich._ requirements for emergency response planning. .c .rt.43 090 .4....-...--
I-ll Hurricanes and tornadoes are two potential threats for which some emergency planning is required. Approximately 2 hurr' canes per year may be' expected to hit the Atlantic coastal States which require emergency response. For individual States, the hurricane frequency ranges frem 0.01 to 0.55 per year. Tornadoes have a very high probability of occurrence per year. A severe tornado can be characterized by wind soeeds of over 200 miles per hour. Such tornadoes are capable of lifting cars off the gicund, tearing roofs and walls off frame houses, overturning trains, and uorcoting or snapping most trees. Emergency actions would probably be taken for such tornadoes. The frequency of severe tornadoes for individual States, ranges em about 0.1 to a per year. Severe reactor accidents are at least 100 times less likely to occur than these other disasters requiring emergency response. ye nevertheless believe, that it is appropriate to develup flexible emergency respense capabilities which will assure that consequences from nuclear reactor accidents are minimized. 1243 091 s ee.
I-12 D. Emercency Plannino Consideratiens Cerived fem Siti e n s Meteorolocical Models and Licensinc Criteria
- 1..Si ti nc As indicated in 10 CFR Part 100 (Siting Criteria),
an applicant for a constructicn permit to build a nuclear power plant must designate an exclusion area, a low population zone (LPZ) and a population center basec upon consideration of pcpulation distribution. The exclusion area must be of such a size that an individual located at any point on its bcundary fur two hours imediately following the onset of a postulated design basis accident fission produ'ct release frem the reactor ~ plant would not receive a total radiation dose to the whole body of 25 rem or 3C0 rem to the thyroid frem radioactive plume exposures. The LPZ must be of such a size that an individual located at any point on its outer boundary who is exposed to tne radioactive cloud during its entire pericd (30 days) of passage wculd not receive a total radiation dose to the whole %dy of 25 rem or 300 rem thyroid. Calculated doses are usually substantially less than these deses. Protective measures are not assumed to be taken to avoid or mitigate there doses curing the denote,d time periods. In addition, site relatec requirements are placed on the exclusion area and the LPZ. The licensee must have c.uthority over all activities within the exclusion area, which nomally requires cwnership of the are. T er w ww-m
I-13 be a reasonable probability that appropriate protective l measures, including evacuation, could be taken for the l residents in the L?Z in the event of a serious accident. l Dose guideline values are not given for the population center, although the expected doses would be less than within the LPZ. Demograohic characteristics within 50 miles of sites are discussed in detail in Environmental Recorts and in Chapter 2 of Safety Analysis Reports for each nuclear power plant and in Reference 1. Assumptions used by the NRC staff to assess conformance with these regulations are centained in various Regulatory Guices (eTg, segulatory Guides.l.3 and 1.4) and the NRC staff's ~ Standard Review plans for Chapter 15 of Safety Analysis Reports submitted by applicants for construction permits and operating licenses. Although various assumptions are utili:ed in this guidance, certain ec=en features are shared: systems containing potentially significant quantities of radio-nuclides are postulated to fail for an unspecified reason, releasing all or substantial fractions of their inventories from their normal location to the reactor clant containment structure;* various installed safety systems in the contain-ment designed to mitigate the consequences of the postulated release, are assumed to be inoperable at the time of the event,
- In particular, for the worst case DBA/LCCA costulated for contain-ment design, ICC" of :he nocle gases and 505 of the radiciacines in the react:r core are presumed to be released frcm :ne core anc primar.
pressure boundary to the containmen:, wnicn is assumed to isola:e and leak at a specified volumetric leak rate. 1243 093 I
I-14 or are assumed to be operating in a degraded mode, or combin-ations thereof; the rbsulting fractional release to the atmosphere is assumed to occur at ground level under extremely unfavorable dispersion conditions, i.e., under conditions such that the c.alculated dose for the given fractional release would not be exceeded more than five percent of the time at the site under review; and dose models which overestimate the dose on a olume centerline for the given release fraction are used in f the dose calculation. For all of these postulated, simultaneously occurring circumstances, 10 CFR Part 100 dose guideline values must not be exceeded at the soecified distances frem the site.
- 2. ;,
Perspective on the implications of these 10 CFR 100 reactor siting criteria for emergency olanning can be obtained by relating the calculated doses to the EPA PAGs, to guidelines for milk ingestion, and to certain meteorological aspects of dispersion in the atmosphere. For ground level releases, without a wind shift, dose decreases with downwind distance (r) -a in proportion to r , where a is between 1.5 and 3, depending on the stability class prevailing at the time.(2)(Stability classes are measures of atmosoheric dispersion and are classified by the letters A through G, with A denoting extremely dispersive conditions (see Table I-1)( )). For the NRC staff assumotion conditions (e.g., class F conditions with low wind 1243 094 p
I-15 1 W U2 O 7 m O o,, O g ma A w- = NZoo e-
- ~
CZ m -a O v C y) v h h Ch C = m
- 5v O
O U2 C Oo O CO O OO O w a .x w y .d O U 3 'I- -f O L,N. .A C. -m .J a a w C a C.c x o .3 'A p > Al =- r.1 m mn 0 02 0 ~ ~ ~~ ""~ a 2 to O L 'D E~ M -p OM 2~E E .C 5 L O Z Z _. J O O -O NO to a Z ca .O. o- - a _-,,,, .c x Je ,2: Q -' .C -* ~ Q C to 2 o v Z cd C; O e a. --~ to D m O Qa .m, m, cc J e - w -' O CO O C > C' ~ r= t ~ O m %~ ..O, hC O 5o 8 M 72 Q= 3: ~ o
- ~O ~a O
T Z: ..O. 3 e. Om "m y2 a G u2 u) ~ ~ O <- .a ~ a o l l c r-' r., -=O t
- =
< m m d. m J A> w ,J O . O. .x' ~ a Jc O .2: y4 e m 0 w d, 0 o. n > C -
- =
r.~r oJ O "x 0- O ~ T N 360 c u x=c e e s o. C = m >0oJ9 O C *"" c= a m l m cQ L z-m 4 4 g eJ .= % a . c .c. co s ~ z y C O 3 hh a e O g 0.~ o ~ ~ %c oD '.: 1 D 0u bG =- $3 o C C => Q b O at b $o; = 0 v. y o >N L-w ~ ~- x0a a c~ my' e. w ~ o Q' ^ y c n @$D e= C 0 "<; F
- o O
. ump .g e ifMb __m_ w p r M 1243 095 I
I-16 speed) and for " average" dispersion conditions (e.g., class D stability), a value of a_ = 1.5 provides a good approxi-i mation for purposes o.f projecting dose rates.ith distance frem an exclusion area boundary T;.ble I-2 and figure I-1 illustrate this dose rate decrease. For illustrative purposes, figure I-l also shews the decrease for values of a_ cqual to 1 and 2. Except for stability class A, which seidem occurs, dose rate should decrease with distance within the 2 1/r and 1/r curves in this figure, barring a significant wind shift during a release period. For purposes of this discussion, dose vs distan:e extrapola-tions of the exclusion radius dose rate' for LWR accidents are of the greatest interest. Table I-2 presents projected uocer bound (no wind shift) values of 2 hcur wiloie bcdy and thyroid doses at various distances given a 25 rem ahd 300 rem dose level at an exclusion radius (r ). For a site with an g exclusion radius of one mile, the upper limits of the preposed ~ EPA PAGs for plume exposures wculd be exceeded within 3 miles ;whole body PAG) and 5 miles (thyroid PAG) of the reactor plant containahnt structure; t.ne icwer limits could be exceeded ~ ~ ithin 8 iailes (whole ::ody)' and 15 miles (thyroid) of the reactor w plant containment structure. For a site with an exclusion radius of. 0.5 miles (about the median for currently licensed plants), 1243 096 ~ ~~
l I-17 TABLE I-2 ~! UPPER SOUND PLUME EXPOSURE PATHUAY PROJECTED 00SES SASED ON 10 CFR PART 100.11 '/ALUES } j t (r/r )-1.5 0 to 2 HR DOSE LIMIT (ret) ETA I r/r0 0 Whole Eody_ THYROID (hrs' .$( I 1. 1. 25 300 0.5 r 1.5 0.54 14 162 0.75 E. 2 0.35 8.8 105 1 3 0.19 4.8 57 1.5 3 4 0.13 3.3 39 2
- 9. -
5 O.089 2.2 27 2.5 ~ 8 0.044 1.1 13 ~_3 E' - 6 O.068 1.7 20 4 E-10 0.032 0.8 9.6 5 ~ 0.017 0.43 5.2 7.5 ),. 15 0.28 3.3 10 t-20 0.011 7 s. 1 NOTES: (1) Dose = Dese co=nitment on alume ce terline. q = Exclusion area boundary, t exclusion radius (2) r f for a given site; r/r, = multiole of exclusion 0 radius; lef thand colu6.n can be read as miles if 0 I r = 1 mile. O 4 (3) Prisumes 100% of noble gases and 50% of radioidines in core inventory released to containment, constant l volumetric leak rate from contair. ment, "five percentile" meteorology, straight line of sight travel of the plume, i and conservative dose factors for plume exposure. y (4) ETA = Estimated time of arrival of plume front based on ro = 1 mile and 2 mph wind speed. Higher wind speeds reduce travel times and calculated doses. 1243 097 ~ - _ u__...
t DOSE FALLOFF WITH DISTANCE 1 (ALONG ACTUAL PLUME TRACK) 1.0 0.8 Relative' O.6 Dose 3 Rate 1 m 0.4 E E o2 1/r 1/ri.5 0.2 1/r 2 N b u I I I -l 0 3 0 0.5 1 2 3 4 5 cc Distance (Miles) r/ro (Any Units) 0 1 2 6 8 10 i i
I-19 these limits could be exceeded within half the denoted distances. Calculated course-of-accident doses could be several times larger than the above values, A second perspective from which to peruse the data in table I-2 is that of the thyroid PAGs for the milk ingestion pathway. The ratio of thyroid dose commitment factor (related to air concentration) for the milk pathway to the inhalation (plume exposure) pathway is of the order of 300 for I-131.* Frcm this perspective it is clear that, without a wind shift during the release pericd, potential dose ccmmitments via the milk pathway could exceed the in estion PAG for tens of miles frem the reactor site for the presumed conditions, given the presence of dairy herds and pasture in the dcwnwind direc : tion. Clearly, wherever there is a catential to exceed a plume exposure PAG for the thyroid, there is a much gres.ter potential to exceed the milk pathway thyroid PAG. Alternately, much lower releases of radiciodine could result in projected doses in excess of the ingestien PAG without there being a potential to exceed plume exposure PAGs.
- For a core releasa.1-131 activity would be about one eighth the t:tal radioicdine activity.
Initially (for a day or so) I-133 or I-135 activities would be dcminant. Thus, although I-131 would dcminate tne projected dose cor=itment rate, the key early indicators for monit: ring purposes would be the hard (1-2 MeV) gamma emissions frca I-135. 1243 099 p
I-20 2. Meteorolocical Consideratiens l I Although actual atmospheric diffusion is unlikely to behave as simple theory would suggest, initial projections of dose during an incident would most likely oe based in part on the simple, theoretical, gaussian plume model ('.e., Pasquill diffusion). Shown in figure I-2 are tnearetical " widths" of gaussian shaped plumes (#) (the concentration of a pollutant at the ; elected width of the plume is about 1% of the center-line concentration). Travel times of plume fronts for different wind speeds are also illustrated in figure I-2. Stability class, wind speed and wind direction might be considerably different at the same time at differ ~ent locations in the vicin-ity of a site and local topography could significantly influ-ence wind patterns. llevertheless, the in[ormation displayed in figure I-2 could be useful for scoping initial emergency response actions, especially for those areas within a couple 7 i-is of miles of a site. For example, for a wind speed of 2 Ec F miles per hour and class F stability ( corresponding do - roughly to tne meteorological conditions assumed for.the worst EE a R case (5".) design basis accident considered for purposes of con-5' u tainment design), a plume front would not arrive at a location two miles downwind'for almost one hour. For this hypotnetical case, given timely warning, and using crosswind travel, an individual could, barring any obstacles, walk out of the potan-su tially. impacted area before the plume front extends to two miles, sm 12 0 100
I-21 5::C n "9 F: ".'i e wtr s.v rysi 4
- Mad
_V W d f*]c gg age. g CO R-e a g g. g. = O ( ~ 5 8~ 8 E d $~ E e O"- N e+ g. e E a E <r 1 s. R. E ~ 4 f-4, WJ t. E-E- Ei g R- [; ..e w D O ~ e 0 $~ Q l k l E- [ n g 9 + 2 N Q R-3- l n O O. < - c., u 2 k = Op. 3 {
- 5. 3 t
~ 4 2 s g-1 3 b O o o a C 7 J s J R. 2 2 o ~, s 2 ~J S-I g 1, l* S 8 2 2 o ~ g 5 [ 8 3 S A R 2 S o e E
- di '.
-o I.,,,, I.,, 5, e ^ a a o*-~** a a o**~** a a o o**~*** o o r e C o d e (3Fil1831N30 3WO7d WOud) (2Jala W) 3ONY1 SIC GNIMSSOBO '413 OL pue 9 '2 10 spaacs ta^ea; ac; sauzp tarr. :~apssoaa pue 'cas/a g put g *( ;o spaacs pup ao; s:uo;; swnto jo saan tare;; saa urous osty j pue J
- s sasse tc ^;;tiqv;s,t un's?c e
ac; 'acua:s;p pu ty;a.*cp si sacn td padeqs uasssnts 30 sy;p p-;ttu moss saaui 1243 101 P-O
I l I-22 since the individual would have to travel for about six minutes to do so. Ger)erally, higher wind speeds result in lower dose rates for a given release fraction (scurce term), but time of arrival of a plume front at a specific distance is shorter. j i e -- In the for' going, on several occasions note was made of the possible influence of a wind shift. Clearly, upon a wind shift the plume exposure dose ccanitment rate of persens in the original downwind direction, due to the passage of a plume, would end, and a different pcpulation dose ccanitment rate would begin in the new dcwnwind direction., NOAA(5) has analyzed National Weather Statien meteorological data across the United States and has presented results in the fonn of graphical displays of the probability of hcurs of 0 ytind persistence in 22.5 and 67.5 sectors (Figure I-3 and I-4). The study concludes that there is an even chance of a sig-nificant wind shift cccurring in the next two to four hours at any given location in the United States. A few general observations are of import to emergency planning and/or response: ... the higher the wind speed, the greater is the tendency for the wind to remain in a given direction. Con- 'versely, it is ir the icwest wind speed categories of calm and 1 to 5 mph taat the least directicn persistence is fcund." 1243 102
1-23 s.n N e4 ' a., _= g -.U,c-1 \\
- \\,. #
Q. '-Q~ 9. - ~ f,-[- g / Jr.- \\*.{.f.,&.--:-.~\\ \\ . N~ (\\ - r\\
- ^
? i. t 3,.\\ 1 2 .~ i s-A i = /sb.: f u _.. ~ ~. 1 \\ g s y y,f. - g s, .. ~ s. u t m.' e_ g c N .~t \\ 1, ~ t 'T i .~~ ~ -, ~::.: -s., g s _.. s ~ ,~ \\ \\. '3 ~ 7 y a,A.. Y C d g (. \\. n w. -r:- \\ \\ ,!~, i v. ~ g . v$* ._I ./ '- .n \\ . _e .f ,7 ~ ,p--**-< is N /- ~. w ac:lZ -\\, ...V;. .y. ~ u=. a, L- \\ \\.~ ,), g a 1./----- ~ Gm -l I. / 2 3 pi ( = .w ~- .e f_,. p' ~j j l_ 1,i s - s o = Q o g g j l I ..__..y I s~ = ~ t n:
- 7.. _. !._.. 1 l
l e 3, =
- r... _
= m_. I = a< I I. c= n,,... I x g = 1 v.- g L .l / u u= i .l t z o e uo l - r ~..... . ~ -. ~.., wm K -{ ~r-5 l &E m Cg m_m e I., s=! t* v. _~ = < a-e< .... / ~ ~ z<~ uu 7 ;. .~. ..Ll,..s. 38a 8.3 ' ~ ~ f x..c ~ j ,,,= 3..: -ee ,. = ,.! l i > I 2
- is P
e_ m = _ e. s = = _.
- L
.x,..>.v e 4, - . =. = ,e ~.. 2=
- 3
.- s 20s =- 2 .. ~ <=d /, i.. >wm a 1243 103 P"
I h l 's i \\ '.\\ 5 2. {.. \\, {.,{ f %[ fp. / 't i ~~ '}~5i \\ \\.. )3 3 s n. c -- -.. _.. _...; i , i, ,..- w e N. 1 ~, t. (gr.~..r j..... !' 3 's 4 j \\a 2 s<..t\\ .1 - - ~ (.3.. -~ 4 I% c \\'%, g ,? .._z--51.
- v..,
4, yx9. 1 \\ -s ("* d y x-i ~. m 34 .p, '$/ l fx, 27 j-[ 14 J.3 \\ i s y ~ ~. \\ >./7
.p... -...-.. _.. 1...,... -.-$.... >,...
, f. .\\ 45 g.p. - 2eff' ,,\\. 3
- 22 I4
} j
- 1. 0 29 l
' %.. w. .,n \\ 'W" ~ nl \\n. ? '. i - s 2.s L,, l ,2 g / 34 \\ 56 4 2.. -.4 - REF.1. VAN Dell 110VEN. WIND PEllSISTENCE PROUAntLITY. N ERLTM-ARL-10. NOAA Alf1 RESOUllCES L ADOll ATORY. f, I ,) ( lf, h SILVEll SPillNG. MD. 20910 j [{ ('g 4 g y a f Qj g, uJ probability of hours of wisid persibtence in a 67h" sector centened on tlie i nvli cat ed lii gliu s.t $0-purcent diaoctioni.. Figuse 84. {l$N](C }2/7$ ese 9
I-25 t and "... wind roses (frequency) that favor a particular sector will also tend to persist in that sector." Three caveats to th'e meteorolooical discussien are worth noting. The first has to do with precipitation. Rainfall could occur either at the time of a radioactive release or some time during transport, possibly many miles away from the source of the release. Rainfall is usually a very efficient scavenger of particles in the atmosphere. Should a radi.cactive release to the atmosphere occur during rainfall, one should expect to find relatively greater ground deposition close to the source of the release, independent of the height of the release, than one would find during clear weather. Under rainy conditions, relatively less air and ground concentrations of radioactive material should be found at greater distances from the source of the release. On the other hand, a release could occur d'uring dry weather yet the release could intercept a rainfall at scme distance E away; at this distance particles could be decosie,ed on the i', J ~ earth, vegetation, structures, water, etc., very efficiently. In a strong rainfall a substantial fraction of decosited radio' active material could even be washed away. Rainfall interception could be the most important meteorological phenomena of concern for the case of a strongly elevated (.. release, such as due to plume rise of a thermally hot Y release which is probable with larger accidents. 8
I-26 The second caveat concerns real world meteorology. As noted earlier, plumes or puffs do not nor ally follow strai;nt lines, especially in low wind speed conditions. Nor do they T.aintain a constant windspeed and stability. Puffs can double back and return from where they came and slow down or speed uo. Cl early, the track of a major radioactive release would be of great interest and concern. As illustrated in Figure 7.15 of reference (3), radiation signals well above natural background should be observed even miles away frem a plume at the center of wnich the dose rate is as low as one rem per hour, and even less. Such plumes could be tracked using aircraft and generally available instrumentation such as Geiger counters and " cutie pies." It is also important to realize that s fu'bstantial amount of energy could be associated with major releases. This energy will tend to 'ift the radioactive material off of the ground and form a cloud ~ plume. If this occurs, tracking of the material could be mucn [.' acre difficult since the wind direction can change dramatically with attitude. 3. Licensino Considerations NRC regulation require applicants for licenses to construct and sperate nuclear power facilities to make accident dose calculations. .a Such calculations take into consideration plant designs and site characteristic. They are based in part on the DBA-LCCA accident scenario. Inherent in the consecuence calculations for the postulated 08A-LOCA is the presumption of "five percentile" meteorology, i.'e., the presumption that atmospnerie dispersicn at a site
- 4%*
y
I-27 at the time of the postulated accident should be more favorable (leading to icwer doses) ninety-five percent of the time. "h Alternately,giventhepostulitedaccident,theoddsareat T least twenty to one against the doses being as large as 'F calculated for the DBA-LCCA. This "five-percentile" meteoro-logy is derived from measurements made at the site during, or ~ previous to, the construction period. It can nominally be characterized by class F stability and very icw wind speeds (e.g., 2 miles / hour or less), i.e., the very conditicns for which a wind shift is most likely. These data are presented in Chapter 2 of current Safety Analysis Reports for each nuclear power facility and are given as funciens of elapsed time and i distance. k The res'alts of the conservative licensing calculations for the DBA-LOCA vary frem plant-to-plant because of plant design and variation in meteorology. For this reason a large number plants were analyzed in order to report the likely range of the con-servative DBA-LOCA doses. Data frcm seventy safety analysis reports were collected and used for this purpose. The seventy plants consisted of.12g separate nuclear units. The resulting distribution of CBA-LCCA doses calculated for these facilities ar9 indicative of clants that are new coerating and plants that will be coeratinc in the near future. An example of the results of such calculations is shown in 1245 107 ~
I-28 figure I-5. As is seen in the figure, the major portion of the radiaactive material will be released in the first few hours, after the ac-ideht. Fortunately, for release durations of more than a couple of hours there will be significant wind shifts and cloud meander (especially associated with the 5% to meteor-ological conditions postulated). Therefore, for purposes of these calculations it was assumed that the dose of any individual would be limited to that of the first two hours after the accident. The results of the analysis are depicted '1n figures I-6 througn I-9. Figure I-6 shows the 2 hour thyroid dose versus distance for the 50 percentile and 10 percentile cases. The 50 percentile curve is the median dose for alt,129 units; thus half of the units had doses less than that indicated and the other half had greater doses. The 10 percentile curve means that 10% of the units had doses greater than that indicated. This figure also shows a rapid decrease in thyroid dose out to almost 10 miles with a leveling off at greater distances. It shows that at ten miles, the 2 hour thyroid dose would be typically aceut a rem and that in a few cases it may exceed 10 rem. Figure,I-7 takes the same data but plots the dose at 10 miles against the cumulative frequency of reactor units. It can be seen that the CSA-LOCA doses were calculated to exceed the lower PAG range for only ~ 30% of the units. Figure I-8 and I-9 provide similar plots for the whole body 1243 108 ev-g--
1 1 I IIIIE IIIIl l 1 I IIlll I I I { F2 m 10 c, zp ~ q P E scw [ 4 E 25 HEM b S 5 i l m n. s s e ~ 5 HEM i 3o-1 1 I I IIIll t i I IIIll l 1 1 IIII 2 3 4 6 10 10 10 10 N DISTANCE (METERS) j p w li o Figuro I-5. Example of Time-Dose-Distance fletationships f.or Thyroid Inhalation Dose 4 From DBA/LOCA (5% Meteorology and Straiglittine Plume Trajectory) ~ l
I-31 l 100 t i i i i I 2 HOUR THYRO!D DOSE 80 E N E3 0 60 b !E oO y u. y 40 P 53 lE 8 20 0 0 5 10 15 20 25 X - THYROID DOSE (REM) I Figure I 7. Cumulative Frequency of Units Versus Dose at 10 Miles for Licensing Calculation of DBA/LOCA at 2 Hours Assuming 5 Percentile Meteorology and Straight Line Trajectory. 1243 110 W "M, -," ' " p m- -- _ _ myww
I-32 6 g g g 2 HOUR WHOLE BCOY COSE 5 E 4 E OQ g 3 7 8 \\ 2 O E 10% 1 50% 0 0 10 20 30 40 DISTANCE (MILES) l I I I 1 0 5 10 15 20 ~ APPROX. TIME OF CLOUD ARRIVAL (HOURS) Figure I 8. Canterline Dose Versus Distance for Licensing Calculation of DBA/LCCA at 2 Hours Assuming 5 Percentile Meteorology and Straight Line Plume Trajectory. 50% Curve is Median of 67 Actual Site Calculations 10% Curve is Highest 10% of Calculations s-
I-33 l 0 ) i i i i i 2 HOUR WHOLE SCOY COSE 30 -U i2 5 u.o 60 >o E c 0. E ~ 40 P 5a23U 20 I I I I I 0 0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 X-WHOLE BCOY OCSE (REM) Cumulative Frequency of Units Versus Dese at 10 Miles for Licensing Calcu Figure I-9. DBA/LOCA at 2 Hours Assuming 5 Ps,,antile Meteorology and Straight Line Trajectory. 1243 112
I-34 dose case. The results are similar tc the thyroid case. J The dose is seen to sharply decrease within 10 miles and to decrease sicwly at greater distances. At 10 miles the whole body dose for the median plant was about 1/10 of a rem and very few plants had doses in excess of 1/2 rem whole body. From 139se results, the Task Force concluded that about a 10 mile Emergency Planning Zone for the plume exposure pathway was justified to assure that predetermined actions would be planned in those areas where PAGs could be exceeded in the event of a release comparable to a design basis accident. ~ .c For the ingestion pathway, figure F-10 was developed showing a distance relationship of potential dose to an infant's thyroid frem milk consumption. As was done for the plume exposure, conservativa calculatioral techniques were used to attempt to bound the results of the ingestien exposure. For example, the straight line trajectory was used with no credit taken for wind shifts..All of the assumptions of the Reactor Safety Study for the calculation of thyroid dose frem milk ingestion were used for th1s analysis. The results of ~ . figure I-10 show that for the CSA-LOCA, ingestion doses above PAG's are unlikely to occur beyond about 50 miles frem power plants. N w. v W D =%g
l-35 50 I i i 1 40 2 wz 2z o 30 ~ w N OO
- z O
P y 20 E O "I-Och A 10 I I r 0 0 10 20 30-40 50 DISTANCE (MILES) I l I f O 1 2 3 4 5 '~ APPROX. TIME OF CLOUD ARRIVAL (HOURS) Figure 110. Maximum Thyroid Dese (Milk Pathway) to Infant Versus Distance, From I 131 for DBA/LCCA Assuming Worst Possible Metecrology and Straight Line l Trajectory. i i I
I I-36 I E. Emercency Plannino Consideration Oerived frem The Reactor Safety Studv (WASH-la00) The Reactor Safety Study (RSS) attempts to provide a detailed quanti,tative assessment of the probability and consequences of " Class 9" accidents. The study concluded that the public risk from nuclear reactor accidents was dcminated by accidents in which there was substantial damage to the reactor core.and that the probabilities of such accidents were very saall.* Since emergency planners are encouraged to develop response plans which will be flexible enough to respond to most accident situations, scme understanding of " Class 9" accidents and the ~ relationships between them and energency planning is needed. The Reactor Safety Study developed the matbematical techniques and data base to provide an understanding of these relationships. To obtain an appreciation for the distances to which or areas within which emergency planning might be required, a perspective on the relative probabilities of certain critical doses as a function of distance from the power plant for these accidents
- Probability of a " core-melt'l) accident was estimated to be approxi-mately 1 in 20,000 (5 x 10-3 per reactor year. There is a large uncertainty en this number.
1243 1i5
7 I-37 is needed. A set of such curves has been prepared for all of the RSS accident release categories (figure I-il). These curves include both Pressurized and Soiling Water Reactor (WR & BWR) accidents. Coses are given for the critical values { for which emergency planners should be concerned. One and 'J five rem whole body doses correspond to the lower range of the PAGs; 50 rem whole body corresponds to the dosage at which early illnesses start to occur; and 200 rem whole body is the dose at which significant early injuries start to occur. As can be seen from figure I-ll, core melt accidents can be severe, but the probability of large doses drops off substanti-ally at about 10 miles frem the reactor. ;5imilarconclusions can be reached by evaluating the other critical organs of lung and thyroid shown in figures I-12 and I-13, respectively. For the lung, tha doses of 5, 25, 300 and 3000 rem were plotted as a function of distance and probability of occurence. For the thyroid, the reference doses of 5, 25, 300 rem, wnich correspond to the lower and upper PAG levels, and the guide-line exposure used for siting purposes are presented. Given a core melt accident, there is about a 70*; chance of exceeding the PAG doses at 2 miles, a 407, chance at 5 miles, and a 30*.' chance at 10 miles frem a power plant. That is, the probability of exceecing PAG doses at 10 miles is 1.5 x 10-5 1243 li6 ~ o
1-38 a 6 6 a. 6.. 66ig 4 e i i e T. 6 . 4 e..g E ~ 1 REM y Q c$ 5 REM 0 0.1 c2 w
- 9
~ 98 g< eb 2m 52 50 REM U$ Mg =. < uo5 D >. 0.01 ie 22 g O 200 REM f I 'I 0.001 1 10 100 1000 OfSTANCE (MILES) Figure 1-11. C iitional Probability of Exceeding Whole Body Case Versus Distance. Probabilities are.cnditional on a Core Melt Accident (5 x 10-5). Whole body dose calculated includes: external dose to the whole body due to the passing cloud, exposure to radionuclides on ground, and the dose to the whole body from inhaled radionuclides. Dose eticulations assumed no protective actions taken, and straight line plume trajectory. 1243 117
I-39 s l 1 ......j g S R EM o-cz 0,1 oa
- i3 eu 25 REM z<
o* wd $2 xw w c:
- u. o j
ou 'e t-2 d5
- i3 0.01 7 7
m O ~ = 300 R EM 3000 REM ~ I 'l 0.001 1 10 100 1000 DISTANCE (MILES) Figure 1 12. Conditional Probability of Exceeding Lung Doses Versus Distance. Probabilities are Conditional on a Core Melt Accident (5 x 10-=). Lung dose calculated includes: external dose to the lung due to the passing cloud, exposure to radionuclides on ground, and the dose to the lung frorn inhaled ~ radionuclides within 1 year. Dose calculations assumed no protective actions taken, and straight lir.e trajectory. ))hb \\ e e e
1-40 t i i i_ .I 1'_ i .i.i ~ 5 REM ~ O Q o s O2 0.1 cw >. c 25 REM 25 Mu O< =b S=2 0 /-# Xc 300 REM
- C O<
>2 &w 52 0.01 QC e g m 0.001 100 1000 1 to DISTANCE (MILES) Conditional Probability of Exceeding Thyroid Coses Versus Distance. Probabilities Figure I-1J. are Conditional on a Core Melt Accident (5 x 10-=). external dose to the thyroid due to the passing Thyroid dose calculated includes: cloud, exposure to radionuctides on ground, and the dose to the thyroid from inhaled radionuclides. Dose calculations assumed no protective actions taken, and straight iine trajectory. ~' 1243 119
I-41 per reactor year * (one chance in '50,000 per reactor-year) frem the Reactor Safety Study analysis. Based'in part upon the above information the Task Force judged that a 10 mile plume 5PZ would be appropriate to deal with core melt accidents. Potential ingestion doses to the thyroid (thrcugh the ccw/ milk pathway) frem core melt accidents are given in Pfigure I-14. The distance. for which emergency planning is needed is not easily determined frem the informatien given in the figure. It is evident that doses can potential 1y be quite high out to considerable distances. The current PAG for milk ingestion is 30 rem thyroid to an individual and 10 rem thyroid to a suitable sample of the population (usually caiculated on the basis of an infant's thyroid). Given a core melt accident, there is a near 100% chance of exceeding the 10 rem thyroid PAG from milk ingestion at 1 mile, about an 80% chance at 10 miles and a 40% chance at 25 miles frem a power plant. A planning basis for milk ingestion on the order of 25 mi'les would therefore approximately correspond to the 10 mile plume exposure distance
- There is a large uncertainty on this number.
i 1243 120 e y
1-42 .I 1r .I L ~ g g e N 5 u. E 1.5 ret,1 w h$ 0.1 - SE_ 15 REM wu ey 30 REM c 2b Cw =
- 2 mw WC
.t-~ RO e u e< 22 -w Q 2 0.01 7 ge x m u. O ~' t: a_ c2 s OC o. 1000 100 0.001 10 1 DISTANCE (Mi!.ES) Conditionoi Probability of Exceeding Thyroid Dose to an Infant V Probabilities are Conditional on a Core Melt Accident Figure 1 14. Thyroid dose calculated is due solely to radionuclide ingestio consumption pathway. Dose calculations assumed no protective actions taken, and stra 1243 121 W %s-l O
I-43 if current FRC guidance were used. h'owever, because the I Task Force is aware that revision of the FRC guides may result in recommendations for certain types of pre-ventive measures (such as putting ccws on stored feed) at projected doses substantially below these levels,* the Task Force chose an ingestion pathway EFZ on the order of 50 miles. s t 3i-
- The recemgended size of the ingestien exposure EPZ is based on an e c revision or mit<
x e' "=~- pathway Protective Action Guidelines by FOA-Bura=u Radiological Health. TheTaskForceuncerstancsthatm'easuressucn$s p acing dairy cows on stcred feed will ' e reccmmencec for crojec=- exposure levels as lou as about 1.3 rem to tne infant thyroid Shau'd the current FRC guidelines te mai.:tained,an E?Z of acout 25 miles wouic be recommended by the Task Force. 1243 122
I-44 F. Examina'ior of nffsi o :-or-onry o- +=r-4vo 'a==enros for Core Melt Accidents A recent study (6,.7) has been published which is of general use to those responsible for emergency response planning for ~ reactor accidents in understanding the " Class 9" accident relationships and specifically the core " melt-through" and ~ " atmospheric" accident classes. This study was undertaken to evaluate, in terms of public radiation exposure and health effects, the relative merits of possible offsite emergency protective measures for response.to potential nuclear reactor accidents involving serious reactor accidents. Three types of protective measures were examined and ccmpared: evacuation; sheltering followed by population relocation, and medical (iodine) prophylaxis. This study was based upon the ?,eactor Safety Study results and methodologies. The conclusions of the study not only give a perspective on the relative meri;s of c given protective measure, the conclusions also confirm the Task Force recommendations on the distances and times for which planning is apprcpriate. ~ 1243 123 M 6 p O
I-45 d i FiguresI -15 dnd Ll6 give the additional perspective of the study on the probabilities and needs for emergency planning in terms or~ the core " melt-through~ and " atmospheric" categories and a range of expected emergency actions. Figure I -15shows the probabilities of exceeding thyroid and whole body PAGs versus distance from the reactor, conditional en the cccurrence of a' belt-through" releasa. The probabilities are calculated for an individual located outdcors, and are presented for both lower and upper PAG levels for each organ. A similar curve is shown in figure I-16 for the"atmospherid' releases. 't The figure indicates that both whole body and thyroid PAGs are likely to be exceeded at very large distances
- from the reactor (and correspondingly over very large areas) if an "atmoscheric" accident were to occur.
Doses in excess of threshold levels for 'early health effects are confined to-smaller areas much closer to the reactor. Therefore, in the unlikely event that an accident of this magnitude were to occur, i responsible authorities might choose to cirect their available I
- Caution must be used in interpreting the large distances indica'.ed.
The RSS consecuence mcdel assumes an invariant wind direction falicwi ; the release of radioactive material. Mcwever, because of the time required by the cloud to travel large distances, it is likelv :nat re wind dirc:tions will, in fact, shift and that the predicted c ' levels _ would not be cbserved at the reported radial distance. Rather, :t-distance applies more closely to the trajectory of :ne releasec cicu.. I243 124 I
1 46 o 4 pi.g. ...g. g. - g
- 5. :
l i,s si , it.
- 1 s
t. 3 2.31 c. t- .2 -3 s; -7 as 4.s \\ c. F- ~2 4 = ]d_ 3 s x .1? fl 7 l:g \\ n t g \\ \\ 1-a s \\ \\ Sjz. 't.r ri \\. -i .7 s ls3 '7
- 7-m
\\ \\ = s -2 d. 3 s. a, 2 ,7 E 3-3 -a r T' o o. s. a t,3 9a e c. "M 4 3.n 14 7s. o-o- = -
- s it. 2,'
2, s, - : l -1 w. o. o so go =o a o 1snjn[.. + =t c.<. =: =., s-s 2 m-a s i:2 25 -: 2 o s.2 3 T
- g ii2 l =2 4 s
V z a 3.: 3 2
- r.+]
3.3 21 :, s4 tsi. 6 71 q.,4.. -s*: sm ~r.~~ ~.., li l 4F11 's:l,
- a. > va g
r ew? -i s
- a ;!s 24
>2 o g = 515 p,2,. 5 - 'm .1. l....l. ....l. 53 C3*% g' h IS*IIMd) 33YIl33 0131Hd50W1Y 1.Yd t N! AID S2Yd ACCS 31 CHM CNV C10Mk1 ONICD;X3 20 u!18941034 W N
- 2. :.
s 14 . a 1.g.5 a_ i ..i.. 2 1 I s, l 6. 4 3 3
- l4I, 3j
!!] 'k,e gj3 r. y *e s o-2 ,3 4.== o. da 3s-5 =. .1g af' 2 L: w ,a m-so 5m-3W(g
- ,2 9
o. 4; g3 2, ae !e 316 .y z.L ; N 4,1 n- , 4 :. \\ \\ s 3 s g.2 .,4 7 -e 2: 2 j y O jd
- 5
-a g pg z s. 1:2 a 3 s / O }35 f$ l ! ', 5 s,* s
- =,
rm /2 x. e -a5 J3 /
- a n s
a:
- 1
- 1 4
I -a, -h o - o. 30 12 h.$ $N ~. ~ me 1-ig t o-7 5$. 4-, -f_i
- 4' e M-E-.
W 32 a : So is I- <.2:
- .1 2;
3s gred 4 I..s'l'g. a -s dz d 1 I o d 8 [,*' f) a dlNt 11Md) 35YI123 WOC 2HL-L13W BVd V NIAl3 sovd Aces rm c.sv mu,u :. icu:x3 :o untsucad s
I-4/ resources towards Timiting the life-and injury-threatening doses to indikiduals in those closer areas. Then, if sufficient resources are available, protective measures might also be implemented for individuals at larger distances for whcm FAGS are, or are likely to be, exceeded. Mean** numbers of projected early fatalities and injuri.es within selected radial intervals, conditional on an 'natmos-pheric" release. are compared for evacuation and sheltering strategies in Mgures I-17 and I-18. Seven strategies are included, as defined in the key to these figures. Strategy 1 assumes that no immediate photective actions are taken. 2, 3, and a are select.ed sheltering strategies. Strategies 3 and 4 represent sheltering for regions in which a large fraction of hemes have basements. Effective exposure i durations to ground contamination for these two strategi.2s j. are 1 day and 6 hours, respectively. Strategy 2 repre-sents sheltering for regions in which most hcmes do not have basements, with 6 hours of effective exposure to ground con,tamination. Strategies 5, 6, and 7 represent evacuation with 5, 3 and 1 hours of delay time, respectively. The results presented in ftgures I-17 and I18 assume a uniforn population density of 100 people per souare mile. The corresponding The mean refers to the average of 91 stratified weather secuences which were used to calculate a frequency distribution of early public health effects. 1243 126 -o e.
Ib 1 . a 5 2 n i. e g i +. 4 sg 5 tae ti - i f . y 1 s e.s. - s a.,
- d. w.
i n.s. e t,c s' e 6, i. eo t s. ei n n s eca c a o 3 ? t..i i, t 5 =. l e. a l se.,. m. e s . a ) t
- s. g
,. m.ui e. e. e g 5 1 f
- ii u l
sa.. mm u s
- s. n a
e 1 Wi 'e 0 t es, s.
- e. s'.l a.
oa 4 w n. aws s. a. a ,. m u. e.- o.. n R d s. a,. ,, 6 i e leeel e.
- t. ee.
c. e s6 l e, t A
- 9. n.
i s V s6 e a ri , u, s a t s p srh !N sat ,. a i e i e. e n .s ? I vu u. ,,l. a o n. t g, l lea no n. .e t e tyy e. .s t l 0 A a e. s i. 3 e a s. 4 s. t. g s.4 1 1 t 0 .w e . p h. l. g e g
- e. w.
g o.g 3 5 A e.is,. .s e.. .o w.. e e4 a. t i ( l ss s. i. r. 3 .., s t 8.a ,4,,w%8I s.
- s. s n
o = t... p4e s
- e. n e
- i..
p. . e t v b em. ,.n %. 4. n , c. a s 4 i e e. ,,i.3, e,. *c e ? ,.s .s .e e4 s4 te 8* i set. iw p s,.spt e l. i. a. a... s a. a.i= .,s, G 6. ov 8 w 4 .. s .i 3 5 ( a sao ,9p ea ' s s i 4 l o s n 3 Il 0 . ig p 3, 4, %6.1 o "e n-t
- e 2
I m.a: 2 a I' s bU f s 8 g 8e
- s 1
s 6 0. 5 Id' s 3 4 te 0 O 0 y 0 0 o ) 8 y U 5 hn 3 1 s
- t t
e
- e
_?~a2E m$.N ut*:gm9A U;gc.z bom,;<>sp. u 66
- h.
9 .a a le Sjj t' a' ",si F
- s<"ot M>" u2 d ta:= >U O n.
..o" .6 fa:. E d r hU( a a a n a 5 = s 2 a = 8 4 s) 5 na*y 6 4 8^ . =. o4 1 i t b : 8 4 f y s. 8 8 c = m. i. I a 8* af
== e. a a 8 8' es s.h s. 88* s e s = me m. s
- a s
s. a
- c. 8Ga 1
s t a ? i. s 3 e n he a .t e te a s. m s l. . w a-i i. .t 1 6 u sa.- i n,, s. 5 . o. a n ted 4 a 4 1 t t p 0 iN e s. s i s t a ie o n m. e. .=... ws. s 1 . sa1 es s e. .e s i s n A as =. d o o u e. g t i. v L s R a. sai= "e h a a. V s seaa 6 t-8 eael B. e4s. e e* S t I r a.i t .t. n. 6. w e T t i. 4 4 Sl m e i s st E iet s w il .
- t o
p ? N i a e 0 44 e
- ws.
a. ypse e. 0
- s..
8 8 ..o s.. laall l. a 0 L - n 1 n
- e. p h..
o e ryf a.
- s. e a
a 1i J s A b s .n I s. idl s e s D an. e 5 A
- a. os.
i a a
- e. m s
t os es w =. o
- t e..s.e.
e H
- e. s u
e ,. 4 .a. i.. e et 8 l te i s p A *r "e e .t ..ai. e sp e w m s. ic s s %II s u e i.. a s. e. n m..6 s s t e .s. 6 u. .s. e.c. i. a s6 is a s . u e.eu4 s 4 s e e .e. ie. i. 4.,,n 6. ie.
- s. s 6, e
- s. i n...
s. a. s w=. t fw e s 5 .e s. .. w po ps 4 .o e.st. se ... a 3 O s 3o s es .. n y s o ee .s 2 npa. sE 3 4 g4) ta sa 6 . aa: n 3 f i 3 sng T =
- a. a 1
t. d so 0 E 0 0 0 e 8 t 1 le lel 5 3 e s b a.w a s h u a aA aiaCm4" U " ".r.mosG wf < Z >__o my>" te-i . a : g c-4 4< E" ?.G,emuo" $ 3c.rt >M6o u*.=o,a *w2 eax e f N45.* N i 1
s I-49 number of projected early fatalities and injuries for any par-ticular site would depend on the actual populaticn distri-bution surrounding the site.
- levertheless, the relative com-parison of numbers for the strategies indicated is nearly independent of the population distribution within a given interval.
Several observations can be drawn from the results presented in figures I-17 and I-18. Most early fatalities resulting frca " atmospheric" ccidents are projected to occur within approximately 10 miles of the reactor, while early injuries are likely out to scmewhat larger distances.* j. Within 5 miles of the reactor', evacuation appears to be more effective.in reducing the number of early health effects than sheltering, as long as the delay time and nonparticipating segment of the population are kept sufficiently small. This distinction is not as apparent in the 5 to 10 mile interval. Throughout both of the intervals from 0 to 10 miles, the importance of a rapid and efficient implementation of either evacuation or sheltering is evident (small delay times for evacuation, small ground exposure times for sheltering).
- Projected early fatalities and injuries in the 15 to 25 mile interval are higher than for the 10-15 mile interval because the interval is t'.4 ice as wide.
i 243 i28 N
I-50 Note that evacuation (i.e., removal of population from hazardous area) with delay times of 1 hour or less will reduce the projected number early public health effects to roughly 0 in any radial interval, and will always be the most effective response measure for a severe accident, if it can be achieved. In the intervals beyond 10 miles, there is little apparent distinction between the effective-ness of evacuation and sheltering strategies in terms of projected early fatalities or injuries. The mean number of early fatalities is 0 in both of these intervals, and projected early ina. ries, although not 0, are greatly reduced for each nf the protective strategies investigated. Several important con:lusions about the relative effective-ness of the protective measures examined, the distances to which or areas within which they might be required, and the time available for their implementation, were drawn by the study frca the results provided by these analyses. For the " melt-through" class, projected whole bcdy and thyroid doses ir excess of ?AGs for those organs are, for all practical purposes, confined to areas within 10 miles of the reacter. Emergency response planning for this type of accident should therefore be primarily directed towards limiting the dose to those individuals located within that distance. Evacuation appears to provide the greatest benefit of any protective measure. 1243 129
I-51 However, sheltering, particularly in areas where most homes have. basements, also offers substantial benefit, and may in Iodine many cases off r an acceptable alternative to evacuation. prophylaxis, if administered in sufficient time, could also offer substantial reduction in the projected dose to the thyroid. ' Atmospheric" accidents could result in the occurrence of sig-nificant numbers of early fatalities and injuries. However, doses in excess of threshold levels for significant early health effects (about 200 rem whole body) are generally confined to areas much closer to the reactor. Therefore, given an " atmospheric" accident, respon$ible authorities should concentrata their immediately available resources on limiting the life-and injury-threatening doses to individuals in those closer areas.* W' thin 5 miles of the reactor, evacution appears to be more effective than sheltering in reducing the number of early health effects, as long as the delay time and nonparticipating fraction of the population can be kept sufficiently smail. Between 5 and 10 miles, this distinction is not as apparent, and. sheltering in areas where basements are widely available (folicwed by rapid relocation) may be as effective as evacuation with relatively s: hall delay times. For all affected
- Then, when time oermits, protective measures might be inclemented for individuals at larger discances for wncm PAGs are, or are likely to 6e, exceeded.
I 1243 i30
I-52 areas within approximately 10 miles of the reactor, the speed and efficiency.'with which either evacuation or sheltering and relocation are implemented strongly influence the number of projected early health effects. For areas beyond 10 miles, there is little apparent distinction between the effectiveness of evacuation and sheltering strategies in terms of projected early fatalities or injuries. Therefore, although protective actions may be required for individuals located in areas fur-ther than 10 miles from the reactor for an " atmospheric" release, the actual measures used and how rapidly or efficiently they are implemented, will not strongly influence the number of projected early health eff.s' cts. 1243 131 e s e e 6 m e. p+
I-63 fjs I f $s %f?: ^ i Ol:?Y! n REFERENCES FOR APPENDIX I 9 D. Sunch, X. Murhhy and J. Reyes. (1) Demographic Statistics Pertaining to Nuclear Pcwer Reacter Si tes. (Oraf t) NUREG-03'3. USNRC Washington, D. C. 20S55 Dec. 1977 Workbook of Atmospheric Discersion Estimates. (2) D. Bruce Turner. USEPA Office of Air Programs, Research Triangle Park, AP-26. NC 27711. 1970 Revision. Meteorology and Atomic Energy - 1968. D. Slade, ed (3) USAEC. National Technical Information Service, Springfield, 'la. TID-24190. 22151 Ooses While Traveling Under Well Established (4) J. A. Martin, Jr. Plumes. Health Physics Jr. V. 32, n.4, pp. 305-307, April 1977. Wind Persistence Probability. ERLTM-ARL-10. I. Van der Hoven. (5) 20910 NOAA Air Rescurces Laboratory, Silver Spring, MD Aldrich,D.C.,Exa.tinatieno[0ffsiteRadiole2icalEner2ency (6) Involyeg Protective Measures por cclear Reac:cr j.cc cen 3 Core Melt, ;IIT, Depar-:.ent c:. Nuclear ingmeerng, y2rcn,1973. (7) Aldrich, D. C., et al, "Examinaticn of Offsite Energency Protectife Measures For Core Mel Accidents,".4.ericr..uclear 5cciety icoical N Meetino, Newacrt Beacn, Ca., May,1978. 1243 i3-e he P e
r + ,,e o
- 11. _..~_..~..-m--.M.
.. _. _ -. -. = - = - - -.. - _ _ _ - -., - ~ - - 1 ->i-T APPE?IDIX II 4 7 BACKGROUtt0 C0f(CERftIttG THIS RE?CRT The ccmmercial nuclear pcwer industry has expanded greatly in the last several years and is expected to grow even larger in the years ahead as more plants go into operation. The industry to date has had an excellent safety record. The Federal government reccgnizes this excellent safety ~ record and the effo-ts by the nuclear industry to continue to reduce even further the likelihoed of accidents. It also recognizes, however, that g the probability of an accident involving a significant release of radio-i ~ active material, although small, is not zero. It has been and continues to be Federal policy to adopt a cautious attitude with respect to the [ u potential of these facilities for the release of radioactive materials r-d. in hazardous quantities. Such emergency' situations are the focus of +. attention of Federal radiological emergency preparedness activities. A. f(RC Reactor Siting and Emercency Planning Reculatiens - S s, The U. S. ftRC, as the agency with the principal regulatory authority for the construction and cperation of nuclear pcwer plants, has long recognized that emergencies could arise in the operation of such plants.. One of its regulations, Reactor Site Criteria (10 CFR 7 Part 100 published in 1962( }} states that a capability for taking ~ protective measures on behalf of the public in the event of a serious +, ;.. II-I j }q} }}} t g @f .1 ..__--_--._.,7 ..7. ~ j 9: n 3 <g,
- 3
~ +, 1 ~ s f4;, r 4 [ s i g
k ~ . y accident should be established within.a region called the low population zone (L?Z) surrounding a nuclear power plant site. Whether a specific nuhber of people can, for example, be evacuited fran a specific area, or instructed to take shelter, en a timely basis will depend on many factors such as: egress routes, availa-bility of sheltering, the scope and extent of advance planning, and the actual distribution of residents within the area. In 1970, explicit requirements for plans to cope with emergencies were published in 10 CFR 50, Appendix E. In accordance with provisions of the Atomic Energy Act of 1954, these requirements are directed to applicants who apply for licenses to operate these facilities rather than to State or legal governments. With respect -I to a planning basis, NRC regulations in 10 CFR 50, Appendix E, do not provide explicit guidance as to the character or magnitude of accidental releases to the environment which should be considered in the development of nuclear facility or State and local government y emergency plans. The Appendix E regulations also go.not include 6 any explicit references to the Icw population zone or other particular geographical areas other than "within and outside the site boundary". They do, however, require that applicants for cor.strudtion permits for these facilities provide sufficient e a II-2 (J - i l243 l ~
information to " assure compatibility of proposed (facility) emergency plans with facility design features, site layout, and site 1ccation with respect to such considerations as access routes, surroundirg population distributions, and land use". Neither the NRC nor the other Federal agencies have statutory authority over State and local governments with respect to emergency planning related to nuclear facilities. In the regulation of nuclear power plants, hcwever, NRC requires licensees to develop an emergency response plan which contains provisions for the protection of the public. The implementation of any protective actions offsite, however, is necessarily the resconsibility of offsite organizations. The NRC requires that the licensee develop procedures for notifying local, State and Federal agencies. NRC also requires that licensees' emergency plans contain agreement reached with local, State and Federal agencies which provide for the early warning of the public and the implementation of any appropriate protective actions. B. Federal Guidance Effort The legal authcrity and responsibility of local, State and Federal governments for offsite response was recognized when 10 CFR 50, Appendix E was published. NRC regulations require, licensees to II-3 1243 135 ~
.w orporate provisions for participation by offsite authorities ,,, organizations whose assistance may be required in the event of radiological emergency in periodic drills to test response plans. ,. the NRC staff gained experience with these requirements, it ..came concerned with the abilities of State and local governments a discharge their responsibilities should the need ever arise. 'nis concern in part gave rise to a Federal Register Notice niich started an Interagency program for providing radiological d d related training to 4.mergency response planning gui ance an NRC exercises the
- , tate and local government organizations.
'ead role in this activity and several Federal Agencies, including Guidance has been published by NRC, EPA and other IPA, participate. . federal agencies for use by State and local governments in developing 'i radiological emergency response plans. It has been Federal policy to encourage planning for a variety of radiological consequence situations "within and cutside the site boundary" and the Task Force reemphasizes the necessity for emergency planners to consider a wide spectrum of situations. 4 Existing Federal cuidance dccuments are constructive in this regard. But these documents are not sufficiently definitive as evidenced by th,e continuing dialogue among Federal, State and II-4 I 1243 136
Existing Federal local agencies and licensees on this subject. guidance which bears on the basis for developing offsite emergency plans is summarized belcw. 1970 "The licensee should give particular attention to 1. protective measures that may be necessary for individuals within the low population zone..."(3) 1974 - The NRC staff's acceptance criteria for preliminary 2. planning at Preliminary Safety Analysis Report (PSAR) review stage refers to a basis of " calculated radiological dose consequences of an airborne release following the most serious cesign basis accident."(4) i 1974 - The NRC's principal guidance document (5) for State 3. and local government emergency planners contains the folicwing under an introductory heading of " Magnitude of the Accident:" "The evaluation of sites and plant designs, required testing programs, and quality assurance for the operation of such facilities all provide substantial assurar$ce that accidents with serious consequences to the public health and safety are not likely to occur. Nevertheless, highly unli'<ely sequences of events are postulated and their potential consequences analyzed by the applicant in the Safety Analysis Repert wtrictt ac'cc=caTrres eacn ap;rltcatter aTt by tre (E) II-5 1243 137
The staff in its Safety Evaluation Report for each plant. (NRC) considers that it is reasonable, for purposes of emergency planning relative to nuclear facilities, to prepare for the potential consequences of accidents of severity up to and including the most sericus design basis accident analyzed for siting purposes." ... The (NRC) recognizes that accidents with more severe potential consequences chan design basis accidents can be hypothesized. However, the probability of such accidents is exceedingly icw. Emergency plans properly designed to cope with design basis accidents would also provide significant protection against more severe accidents, since such plans provide for all of the major elements and functions of emergency preparedness. An added element of confidence can be gained, however, if States and local governments assure that their plans for responding to radiological emergencies are ccordinated with their plans for dealing with fl.oeds, earthquakes, or other disaster situations which might necessitate large scale displacement of people and the provision of shelter, food, medical aid, and other emergency Ccmmunications, traffic control, evacuation, public services. notification and other emergency res;cnses will tend to be II-6 )20b \\b0 6 *e w p
the same whether or not the emergency involves radiological considerations. The (Department of Energy's; RrJ F: logical Assistance Program (RAP), the Federal Interagency Radiological Assistance Plan (IRAP);and other Radiological Emergency Assistance Plans, which are a part of the Federal capability, i provide significant additional emergency resources in the event 5 of a serious accident." s This introductory text in the " Guide and Checklist"(5)- .g document was written for the express purpose of providing .}.v interpretive guidance to the meaning of the enumerated t (7 checklist elements in this document. b s <.. 3 7 1'. G 4. 1975 - With respect to evacuation as a protective measure, F applicants are requested to provide '.' plats showing projected 't 23 t ground-level doses for stationary individuals, -- resulting j-from the most serious design basis accident analyzed in the f 1 Safety Analysis Report. These should be based on the same I s: isotopic release rates to the atmosphere and the same ?s dispersion medel as are acceptable for use in Chapter 15 j of the PSAR for the purpose of showing conformance to the f. siting dose criteria of 10 CFR Part 100."(6) i 3 ~ II-7 y 1243 139 ~ ' 9 we, e- -~ esee..
5. 1975 - With respect to the levels at which emergency actions should be initiated, EPA issued as Agency guidance, portions of the " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" which provided PAGs for plume exposure and applicat1on procedures for these PAGs.( ) These bear on the areas or distances for which plans might be implemented. 6. 1977 " Planning and implementation of measures to cope with plant related emergencies outside the site boundary with particular emphasis on the low population zone should be a coordinated effort involving the 11censee, and local, State, and Federal agencies having emergency responsibilities."( C. Reactor Accident Considerations J ^% Current NRC regulatory practice requires that events which may be anticipated to occur one or more times during the lifetime of a facility lead to no significant releases of radioactive material to the environment. No design or mode of operation is, hcwever, entirely -isk free. Despite the ef forts made to prevent accidental releases of significant quantities of radioactive material, the possibility does in fact exist that such accidents may occur. Each application for a license is acccmpanied by a detailed assessment II-8 12k3 \\ W
of such pcstulated accidents, and NRC staff performs an independent evaluation of these accider.ts before a nuclear facility license is granted. The NRC staff has provided; guidance to appifcants as to the type of accidents to be considered in the design of nuclear power plants (see for example, Sections 2.3 and 15 of Regulatory Guice 1.70(9) and I particJiarly Table 15-1 of that guide). The recommended approach by the NRC staff is to organize the postulated accidents to ensure that a broad spectrum of events have been considered and then to categorize the event: by type and expected frequency so that only the limiting (i.e., more severe) cases in each group need to be quantitatively analyzed. NR.C staff has categorized postulated acciderts into four major groups as follcws: 1. Events of moderate frequency (anticipated operational occurrences) leading to no significant radioactive releases frem the facility. 2. Events of Icw probabfif ty with potential for small radioactive release frca the facility. II-9 1243 \\
5. 1975 - With respect to the levels at which emergency actions should be initiated, EPA issued as Agency guidance, portions J of the " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" which provided PAGs for plume exposure and application procedures for these PAGs.( ) ' These bear on the, areas or distances for which plans might be implemented. 6. 1977 " Planning and implementation of measures to cope with plant related emergencies outside the site beundary with particular emphasis on the low population zone should be a coordinated effort involving the licensee, and local, State, and Federal agencies having emergency responsibilities."( } .s.e' C. Reactor Accident Consideratiens Current NRC regulatory practice requires that events which may be anticipated to occur one or more times during the lifetime of a facility lead to no significant releases of radioactive material to the environment. No design or mode of operation is, however, entirely risk free. Despite the efforts made to prevent accidental releases of significant quantities of radioactive material, the possibility doe,s in fact exist that such accidents may occur. Each application for a ifcense is acccmpanied by a detailed assessment }}43 lk2 M4 y
of such pcstulated accidents, and NRC staff perf1rms an independent evaluation of these accidents before a nuclear facility license is granted. The NRC staff has provi ed guidance to applicants as to the type of accidents to be considered in the design of nuclear power plants (see for example, Sections 2.3 and 15 of Regulatory Guide 1.70(') and particularly Table 15-1 of that guide). The reccmmended approach by the NRC staff is to organize the postulated accidents to ensure that a broad spectrum of events have been considered and then to categorize the events by type and expected frequency so that only the limiting (i.e., more severe) cases in each group need to be quantitatively analyzed. NRC staff has categorized postulated achidents into four major groups as follows: 1. Events of mcderate frequency (anticipa m cperational occurrences) leading to no significant radioactive releases frca the facility. 2. Events of low probability with potential for small radioactive release frcm the facility. II-9 )]hb \\ 5 he h 'v n.. --w
Events of very Icw probability with potential for large 3. radioactive releases from the facility and whose consequences are evaluated to pstablish the performance requirements of engineered safety features and to evaluate the accepta-bility of the reactor site. These events, scme of which assume unlikely failures or fission product releases art referred to as design basis accidents (DBAs). A fourth grnup of accidents, the so-called " Class 9"* 4. accidents, which include any situation not specifically included in the foregoing groups of events and which typically are represented by some ecmbination of failures which lead to ceremelting and/or contair. ment failure. Theselargereventsaregeneral-Jkconsideredinthe regulatory process by reducing their probability of occurrence to acceptably Icw values through design This of the plant and its engineered safety features. group includes external events such as severe natural phenomena as well as accidents initiated within the The first three groups have also been divided into eight categories in some The eight categories plus a " Class 9" category are accident assessments. defined in the pr'oposed Annex to Apcendix 0 to 10 CFR Part 50 dated (Also listed in MUREG 0099, Regulatory Guide 4.2, December 1, 1971. Appendix I). II-10 1243 144 ' ' - = w-w= -w w ww , wh =e g',Mw-4 w w w w
facility. Unlike groups 1 through 3, the consequences of events in group 4, are not specifically analyzed in most applications. l One design basis accident in the third group routinely considered in the safety analysis performed by the staff is a loss-of-coolant accident (LOCA) where it is assumed that a large fission product release frem the containment also occurs. The analysis of this accident is used in connection with the site suitability evaluations done to establish compliance with 10 CFR Part 100 of the NRC regulations by comparing computed accident consequences with exposure guidelines given in the regulations. The Task Force considers the events described in NRC Regulatory Guide 1.70 as a useful source of information on the ty'oe of events in groups 1 through 3 above. Each application will have detailed infor-mation on these possible events, including important plant and site-specific factors that affect the probability and consequences of accidents. Safety Analysis Reports submitted by licensees are not likely to include a discussion of Class 9 accidents. Other documents, such as the Reactor Safety Study (10), discuss the Class 9 type ~ accidents and their consequences. The Task Force believes that the findings on types of severe accidents reported in WASH-1400 provide a useful supplement to the Safety Analysis Reports in developing a basis for emergency planning. II-11 1243 145
The current version of NRC Regulatory Guide 1.70 requests applicants to provide two separate analyses of. accident consequences: one using conservative assumptions to verify that plant design is adequate and a second using best.' estimate assumptions. One purpose for the latter assessment is to illustrate the margins of conservatism used in designing plant engineered safety features. This provision is a recent addition and consequently there are few analyses of this type actually available. Therefore, whfie the nuclear facility Safety Analysis Report will contain a great deal of information on credible accidents and how they are acccmmodated by design, there is likely to be little information provided on the excected consequences of such initiating events. Best estimate consequences of a number of representative initiating -1 events are addressed in the staff's environmental impact statements. The Task Force has reviewed the summary information on accident cc.nsequences provided in connection with these statements and we conclude that these best estimate analyses are too ifmited in scope and detail to be useful in emergency planning. It is apparent, however, frem these analyses as well as frem the NRC Regulatory Guide 1.70 analyses, that best estimate consequences are likely to be a factor of 10 or so smaller, frcm the standpoint of meteorological considerations alone, than the consequences of , 11-12 j243 ikb ~ M-
accidents as typically presented in Safety Analysis Reports and in NRC staff safety evaluation reports for.the purpose of site and plant design feature evaluation. D. Establishment of the Task Force To prepare adequate emergency response procedures, basic information regarding an accident, such as the time characteristics of an accident, the radioactive material release characteristics, and the extent of the area potentially imcacted is required. Past practice has been to use a spectrum of accidents, including design basis accidents for emergency response planning. These accidents, hcwever, were developed fer the specific purposes of reactor siting and the design of containment and engineered safety features. Further, the description f the DBAs in Safety Analysis Reports does not always contain the information needed for developing emergency response plans. In addition, since the publication of the Reactor Safety Study in 1975, there_has been some concern and confusion among State and. local goverment emergency response planning and precaredness crganizations as to how the accidents described in the Reactor Safety Study relate to emergency planning. II-13 h 1243 147
As a result of some perceived confusion in how accident analyses should relate to emergency planning, the' Conference of (State) Radiation Control Prcgram Directors passed a resolution in 1976 requesting NRC to "make a determination of the most severe accident basis for which radiological emergency response plans should be developed by offsite agencies." Additionally, the NRC and EPA received correspondence frem a few States, and local governments in this regard. In response to this dialogue, a Task Force consisting of NRC and EPA representatives was assembled to address this Conference request and related issues in November 1976. The Task Force interpreted 'the request as a charge to provide a clearer definition of the types of radiological accidents for which Stat'es and local governments should plan and develop preparedness programs. II-14 1243 148 9 O
Appendix II e REFERENCES 1. Title 10 Code of r deral Regulations, Part 100 Reactor Site e Criteria. 2. Radiological Incident Emercency Resconse Planning, Fixed Facilities anc iranscortation: Interacency Resconsto111 ties, Federal Preparecness Agency, General Services Acministration, Federal Register Notice, Vol. 40, No. 243, Decemcer 24, 1975. 3. " Guides to the Precaratic, of Emercency Plans for Production and Utilization Fact i1 ties, Decemoer 1970, U. S. Atemle Energy Commissicn. 4. " Standard Review Plan for the Review of Safety Analysis Recorts for Nuclear Pcwer Piants," Section 13.3 - Emergency Planning, NUREG 75/087, Septemcer 1975, U. S. Nuclear Regulatory Cccmission. 5. Guide and Check List for the Develoccent and Evaluation of State and Local Government Racioloc1 cal imercency Resocnse Plans in Succort of Fixeo Nuclear facilities, NUREG 75/iil, Dec. 1974, U. S. Nuclear Regulatory Ccemission. 6. " Standard Format and Content of Safety Analysis Recorts for Nuclear Power Plants, LWR Ec1 tion," Section 13.3 - Emergency Pianning, NUREG 75/094 (Rev. 2), Septemoer 1975, U. S. Nuclear Regulatory Commission. 7. Manual of Protective Acticn Guides and Protective Actions for Nuclear Incidents. E? A-520/ i-7 5-001, Septemaer, 1975, U. S. Environmental Protection Agency. 8. " Emergency Planninc for Nuclear Pcwer Plants," Regulatory Guide 1.101, Rev. 1, Maren 1977. 9. " Standard Format and Content of Safety Analysis Recorts for Nuclear Power Plants. LWR Ecition," Regulatory Gulce 1.70, Rev. 2, Septemoer 1975, U. S. Nuclear Reguiatory Commission. 10. Reactor Safety Study: An Assessment of Accident Risks in U. S. Commercial Nuclear Pcwer Plants, (NUREG-75/014), Octooer 1975, U. S. Nuclear Regulatory Ccemission.(WASH-1400), II-15 1243 149
APPENDIX III RELATED ISSUES CONSIDERED BY THE TASK FORCE Certain issues related to providing a more definitive planning basis were considered by the Task Force. These issues were examined in the light of existing Federal guidance and particularly in light of guidance premulgated by the former AEC regulatory arm (Now the NRC). There are four principal issues: A. Issue: '4hether and to what extent, so-called " Class 9" events having consecuences beyond the most serious design basis accidents analyzed for siting ourcoses, should be considered in develooing emergency olans. Cc=mentary: The Task Force believes that States should be encouraged to develop a breadth, versatility and flexibility in emergency response preparations and capabilities - and that some-consideration of Class 9 events in emergency planning is consistent with this view. Further, the potential consequences of improbable but nevertheless severe power reactor accidents, while comparable in scme sense to severe natural or man-made disasters which would trigger an ultimate protective measure such as \\24h \\b0 ^ ~
evacuation, do require some specialized planning considerations. We do not suggest that these specialized planning considerations Rather, we reccmmend are or ought to be, excessively burdenseme. that they be considered and develooed as a matter of prudence. The Task Force recognized frcm the start that there is no specific design basis accident or Class 9 accident scenario which can be isolated as the one for which to plan because each such accident would have different consequences, both in nature and degree. It is for this reason that NRC and EPA have encouraged State and local agencies to concentrate their efforts on devising response preparations and capa-bilities that are versatile and that also take into account the unique aspects of radiological. accidents. The Reactor Safety Study (RSS)(2) provides a detailed assessment of the probability and consequences of Class 9 accidents. Various aspects of that study have been debated by reviewers. Additional programs are underway to extend or refine the study. It should be noted that the RSS is based on an analysis of two, specific reactors, and the consequences presented are based on a spectrum of data compiTed frcm many sites. The report therefore is of limited use in dealing with plant / site specific factors. III-2 1243 151 N
Nonetheless, the RSS provides the best currently available source of information on this subject. The Task Force had to decide whether to place reliance on general emergency plans for coping with the events of Class 9 accidents for emergency planning purposes, or whether to reccmmend developing specific plans and organi-zational capabilities to contend with such accidents. The Task Force believes that it is not appropriate to develop specific plans for the most severe and most improbable Class 9 events. The Task Force, hcwever, does believe that consideration should be given to the characteristics of Class 9 events in judging whether emergency plans based 'primarily on smaller accidents can be expanded to cope with larger eve'n s. This is a means of providing flexibility of response capability and at the same time giving reasonable assurance that some capability exists to minimize the impacts of even the most severe accidents. For example, if we are dealing with a very large release of radioactive material, the principal goal is to prevent serious adverse health effects to individuals. The measures required to min'imize health effects and to cope with secondary effects of a large accidental release (such as III-3 1243 152 M
land or water contamination, nd the housing and feeding of any people required to be relocated for substin:ial time periods) would, in all likelihocd, require the involvement of Federal agencies in addition to State and local governments. The planning basis recommended by the Task Force therefore includes some of the key characteristics of very large releases to assure that site specific capabilities could be effectively augmented with general emergency preparedness (response) resources of the Federal government should the need arisa. NRC and other Federal agency emergenlcy planning guidance has perhaps been misinterpreted as reflecting a position that no consideration should be given to so-called Class 9 accidents f'Jr emergency planning purposes. The Task Force, after considering the published guidance and available documentation,U- ) concludes that Class 9 accidents have been given scme consideration in emergency planning. It has been, and continues to be the Federal position that it is pas,sible (but exceedingly improbable) that accidents could occur calling for additional resources beyond those that are identified in specific emergency plans developed III-4 i2A3 153
to support specific incividual nuclear facilities.
- Further, the NRC and Federal position has been and continues to be, that a.s in other disaster situations, additional rescurces would be mobilized by; State and Federal agencies.
B. Issue: Is there a need to olan beyond the Low ?oculation Zone? Ccementary The Low Population Zcne (LPZ) is determined in accordance with the requirements of NRC Reactor Siting Criteria,10 CFR Part 100(5) While the consequences of postulated design basis accidents would be expected to be substantially lower than the guideline values of 10 CFR Part 100, there are three reasons why some planning beyond the LPZ is useful: d9,. First, if an accidental release were as severe as the design basis releases analyzed for purposes of 10 CFR Part 100, doses could bs above the Protective Action Guide (PAG)(0) levels beyond the L?Z. In this instance, the responsible officials should take reasonable and practical measures to reduce expcsures to individuals beyond the LPZ. III-5 12a3 154 Hwe e
Second, the deposition of radioactivity, and its subsequent uptake in foodstuffs such as milk products could be significant beyond the LPZ even if the plume exposure pathway doses did not exceed the PAG level at the LPZ cuter bcundary, because of the reconcentration of certain radionuclides in the food chain. Emergency protective measures in that situation should be taken to minimize exposures frcm the food chain via the ingestion pathway. Third, there is a very small probability that releases larger than those frca design basis accidents used in evaluating the acceptability of the reactor site could occur which could have consequences substantially in excess of the PAG levels outside the LPZ outer boundary. As di,scussed in Issue "A" n.. the Task Force concluded that such larger accidents should be considered in developing the basis on which emergency plans are developed. ~ The Task Force considered tnese factors in establishing the size of the emergency planning zone. Two basic options were considered. One option was to develop site specific guidance based on the icw population zone (LPZ) with some modifications to better assure that actions could be extended beyond the LPZ if needed. The second option was the concept of a planning III-6' 1243 ISS
area completely independent of the L?Z. The Task Force recognized that the LPZ is included ~in NRC regulations for siting of nuclear facilities, and is closely connected todesignbasisacckdentconsecuences. We also recognized that actual emergency response actions would be based on proposed Prctective Action Guides. Given these factors, the Task Force concluded that the concept of Emergency Planning Zones (E?Zs) around each nuclear pcwer f!cility would best serve to scope the desired spectrum of situations for which emergency planning should be accomplished. E?Zs for both the " plume exposure pathway" and the " ingestion exposure pathway" are proposed. The separation of this can' cept frca NRC siting considerations is discussed in Issue D. While the Task Force recognizes that there are site-to-site variations in LPZs, due in part to varying features of the plant, the Task Force concluded that the size of the E?Zs need not be site specific. The principal reason for this is that the size of the L?Z is determined primarily by the type and extent of engineered safety features installed in the reactor plant and their response to design basis accidents. The loss o'f either some or all engineered safety features are III-7 1243 156 wwme.
postulated in Class 9 accidents. If the engineered safety features are lost during an accident, then the LPZ has no meaning with regard to the size of the areas around the plant in which emergen y response would be appreoriate. A principal aim in establishing EPZs is to foster a breadth, versatility and flexibility in response preparation and capabilities in a systematic manner. Frem the standpoint of general emergency planning guidance, emergency plancing needs seem to be best served by adopting uniform Emergency Planning Zones for initial planning studies for all light ~ water reactors. C. Issue: Whether there is a conflict between Prctective Action Guides for clure ex osures and dose criteria for sitina and design of nuclear ecwer facilities. ' ' Commentary The Reactor Site Criteria (10 CFR Part 100) require that an applicant identify an area surrcunding a nuclear power reactor, defined as a Lew Population Zone (LPZ). The consequences of the most severe " design basis accidents" analyzed for siting purposes should not resuit in exposures in excess of 300 rem to the thyr 6id frem radioicdine exposure or 25 rem to the whole body for an individual located at any point on the outer boundary of the Low Population Zone (LPZ). III-8 i24.5 15/
A N M /f Protective action guides (PAGs) for plume exposure have been p !I,'aJ provided to State and local government agencies for use as gr -:o c.PA agency guidance jn developing State and local government .p a- ?5I radiofogical energency response plans for areas arx nd Q. g [. nuclear facilities. One might reasonably ask whether it p spe.. yM is inconsistent for the Federal government to recommend 4..6%.n the development of plans to implement protective actions h.h at projected dose levels icwer than the projected doses y.N $g associated with siting criteria. The discussion that <iWr ki$. ' follows reviews this issue. lM W l.1h. .g % The dose guideline values in 10 CFR Part 100 do not constitute / tap.g,l-acceptable limits for emergency doses to the public under .a -J iih.Qi accfdent conditions. The numerical 1 values of 25 rem whole '~ ~~ .~ t a ' 34 2 i,- 5:?i body and 300 rem thyroid can be considered values above 1.Ch.\\ yg which prevention of serious health effects wculd be the u.r. .a 18 paramount concern. Goed health physics practice would @Q3.,:' t'i ~ indicate that radiological exposures of these magnitudes .s L should not be allcwed to take place if reasonable and 7.y.TF;l p'ractical measures can prevent such exposures.. p, % - 7
- L
[
- .g.I' The assumptions used for siting purposes in. calculating
- w. rc.
.c:p
- Cgg, the doses that could result frem design basis accidents
= .s $ id.- are conservative. The actual doses that would result p ,.6 .sr 9g.- III-9 .N. e- .Y;.
- a 3
.- Q 6 .w- ,./" OI
. _ =. from releases postulated to occur frem a design basis accident therefore would be expected to be much lower than the dose guidelines of 10 CFR Part 100 under mest meteorological conditi$ns. The inhalation and direct exposure doses frca the releases postulated for design basis accidents are not likely to exceed the PAG levels beyond the LPZ under average meteorological conditions. It has been, however, the NRC's position that a spectrum of postulated conditions be considered in emergency planning including adverse meteorological conditions. P.rotective Action Guides were devised for purposes of dose savings and are defined as, the projected absorbed dose to individuals in the general population that warrants protective action following a centaminating even Emergency response plans should include them as trigger values to aid in decisions to implement protective actions, and responsible officials should plan to implement protective actions if projected doses exceed the PAGs. The PAGs, which have numerical values smaller than the 10 CFR Part 100 guidelines *, are decision
- The PAGs for the plume exposu e pathway are expressed as a range of 1 to 5 rem whole body dose and 5 to 25 rem thyroid dose to individuals in the population.
PAGs for the ingestion exposure pathway have no parallel in the 10 CFR Part 100 ~ guidelines. III-10 1243 159
aids in devising best efforts, considering existing constraints. They have been set at levels belcw those that would prcduce detectable short term biological effects End at levels that would minimize long term biological effects. In the event of an accident they should be considered as criteria against which avafiable options for various types of emergency actions can be weighed. Officials responsible for implementing the protective actions must take into account constraints that exist at the time and use professional judgment in deternining the actions appropriate to protect the public. The nature of PAGs is such that they cannot be used to assure that a given exposure to. individuals in the population is prevented. In any particular response situation, a range of doses will be projected, principally depending on the distance frca the point of the radioactive release. Scme of these projected doses may be well in excess of PAG levels and clearly warrant the initiation of any feasible protective actions. This does not mean, however, that doses above PAG 1evels can be prevented, or that, emergency response plans should have as their objective preventing exposures above PAG 1evels. Furthermore, PAGs represent only trigger levels and are not intended to III-ll }2/,3 100 e 4
represent acceptable dose levels. PAGs are tools to be used as a decision aid in the actual response situation. As discussed above, PAGs and Part 100 dose guidelines servedistinctlysbparatefunctions. The concept of E.wrgency Planning Zones (EPZs) introduced in this report is an attempt to provide guidance on the areas for which offsite officials should be prepared to.aa%e judgments using the PAGs, to initiate predetermined actions. D. Issue: Whether the cuidance in this document for offsite emergency olanning can be secarated frem sitino considerations in the NRC licensing crocess. Commentary .f 't The NRC siting criteria as related to accidental releases of radioactivity are given in 10 CFR Part 100 of the Federal regulations, and are supplemented by the Statement of Considerations published with this regulatien in 1962 and in various regulatory guides and standard review plans used by the NRC staff. These criteria are used in the review of applications for nuclear pcwer plant construction permits, operating licenses and operating license amendments. The evaluation performed under 10 CFR 100 primarily involves; (1) assuring that possible effects of all relevant natural and man-made phenomena on the nuclear facility have been III-12 l243 161 P O
identified and expressed as design conditions for the faciiity, (2) de?ermining that adequate engineered safety features have been provided to assure that postulated releases of radioactivity resulting frcm design basis accidents will not lead to radiological exposures that are in cxcess of the numerical guidelines of 10 CFR Part 100 at specified o'ffsite locations, even under adverse meteorological conditions, (3) evaluating the distance to the nearest densely populated area to a11cw calculation of the offsite location at which certain of the Part 100 exposure guidelines must be met, and (4) evaluating the general current and projected population density around the proposed facility out to abcut 30 miles. The first three evaluation areas are reexamined at the operating license review stage and occasionally over the plant lifetime as facility or site conditions change. The fourth area (population density) is only evaluated in a prospective manner to assure the use of icw population density sites when such are available and is generally not reexamined. The objective of the evaluations performed during the Part 100 siting review is to assure that the risk from any accident (including a Class 9 accident) is low. III-13 1243 162
The definition of the Low Population Zone (LPZ) in 10 CFR Part 100 states that it is an area which contains residents, the total number land density of which are such that there is a reasonable probability that protective measures could be taken, in their behalf in the event of serious accident. The outer boundary of the LPZ is one of the locations at The outer which Part 100 exposure guidelines must be met. boundary of the LPZ must also be less than a fixed fraction of the distance to the nearest boundary of a densely populated These center containing trore than about 25,000 residents. are not in practice siting constraints because restrictions on the 2 hour exposure frcm design basis accidents at the site (axclusion area) boundary.; generally provide ample time to tak'e action within a few milks to cope with postulated design basis releases and because additional engineared safety features could be added to the facility design, at some additional cost, to allcw the outer boundary of the LPZ to be as small as the site boundary. The current NRC staff evaluation of emergency plans for a particular facility is substantially independent of the The staff review includes facility siti'ng criteria. emergency plans and plans for at least the offsite area referred to in 10 CFR Part 100 as the Low Population III-14 1243 163
Zone (LpZ) and in current ifcensing reviews often extends to substantially longer distances, particularly for the ingestion pathway. Emergency plans are reviewed by the NRC staff durind the construction permit and operating license review stages and audited during the plant lifetime. Emergency offsite response to large accidents may be less effective for sites located in an area of general high population density. Such sites, which may have adequate engineered safety features to meet the explicit criteria of 10 CFR Part 100, tend to be eliminated by the NRC staff guidelines on the general population density around prospective sites. We recognize that there would be a reduction in exposures through the emergency response of the facility staff and local authorities even without planning. This it based on experience in coping with more ccmmon emergencies such as those associated with large chemical releases or dam failures. It seems reasonable that some additional reduction in exposures may be obtained by certain planning activities related to emergency preparedness at any site. However, the reduction in exposures frem planned actions would be difficult to take into account in a quantitative or q'ualitative way in siting reviews. III-15 1743 T64
In view of the above we conclude that although enere is an indirect relationship between siting and emergency planning, the two can and should be considered separately in the NRC licensing process. Some clarification of the NRC regulations may be desirable to make clear the separation of these issues in tha licensing prccess. e O o e 4 9 ese e e III-16 S 34
Appendix III REFERENCES l 1. Radiological Incident Emercency Resconse Plannino, Fixed Facilities and Trans:cr:at cn: interacency Aesconsic:lities, feceral drecarecness Agency General Services Acministratten, fecerai Register Notice, Vol. 40, No. 248, December 24, 1975. 2. Reactor Safety Studv: An Assessment of Accident Risks In U. S. Commercial Nuclear Pcwer Plants, (nUREG-15/Gia), Octocer 1975, WASH-la00, U. S. Nuclear Regulatory Ccmmisslun. 3. Disaster Ocerations A Handbeck for Lccal Governments (CPG 1-6) July 1972, & Chance.10. 1, June 19/4, Defense Civ1: Prepdrecness Agency. 4. Federal Rescense Plan for Peacetime Nuclear Emergencies (Interim Guidance) Acril 1977, Feceral Prepar'ecness Agency, General Services Acministration. 5. Title 10. Code of Federal Regulations. Part 100 Reactor Site Criteria. 6. Manual et Protective Action Guides and Protective Actions for Nuclear Inc1 ents, d?A-220/1-75-001, Septemcer, 1975, U. S. Environmental ?rctaction Agency. M p l)iIL k$h h m.... I b 5" bc [, 1 65 e e e III-17 g_
.. m,: r. m.m a .o...~., ;; c; mc soa. ua y,3,uveu,nagent37en,et,wis:CN l a t.its .'d BIBLIOGRAPHIC C ATA SHEET ';UREG-0595 EPA 520/1 73 015 .h
- 4. ri r u an o Su a Ti T u a os v.,,~ N..<==~ =,
- . 'L e-e
- } f' PLAtittitiG BA5IS FCR THE CE7ELCPME:iT OF STATE af40 LOCAL
, l.*. GOVERtiM.E IT RADIOLCGICAL EMERGE? ICY RESPC:iSE PLAliS IlI
- s. aEC PiENT s AC:zSSiCN r.o.
.d i SilPPCP.T OF LIGHT WATER liUCLEAR PC',4ER PLAtlTS - q e4d
- 7. Auf wo a ts: F. L. Galpin, E?A - Office of Raciatien ?regraming
- 5. o r5 "EacaT :0v'LE *E 3 H. E. Collins, ilRC - Office of State Pr grams l "19 / 3
^a h.ig*- q v t,.. a c _ n!O t* . ru s t.- n as
- !.. ' a s, hso*a-hooi s a d aa
'*ovember i i;
- 9. PE RFCAMING C AGANIZA TICf4 N AME ANO V AILING ACO R ESS. sac voe 1.o CJoes OA TE agaORT 'SSLEO uc8 tn l*ssa dN U. S. ituclear Regulatory Ccemission December 1978 P
Office of State Programs
- 6. ILeove 0,anet l
' 'Jg , dashing :n, D. C. 205. l t.% a w
- 4
8.ILeave atana/ I
- 'Nr:.O..
l
- 12. SPCNSORING CRGANIZATIC4 N AME AND M AiUNG ACo RESS IIacevoe 1.0 TJoet a-. F
- 10. PROJECT / TASK /WC A< LNs T N o a
7-i7;. l ti' e.
- 11. CON TRACT NO.
N' e V.I.$!. $.N.5 JM
- 13. TYPE CP REPORT PE.iCO Gov E Ec uncivs,ve satest
%$'7 7.f.}}}t NRC/ EPA Task Force Report November 1975 - tiovember 1973 ,wr ...d
- 15. SUPPt. AMEN TAR Y N OTES
- 14. /Le ave ot ** * /
l .. Py I q' t - - f
- 16. A8STR ACT 700 ores or.esst l
s'~JE This report suggests a planning basis for State and local government emergency organi:a ; R$. tions to detemine the sce;e of planning efforts for nuclear powe? 'lants. Ice Task l @ffx Force detamined that a specific singic accicent could not be ider<.!fied as the i planning basis. Instead, the Task Force recommended establisnin, two generic Emergency ^! M Planning Z:ne'; (EFZs) ar:und lign: water nuclear power plants. 'be inner :ene of abou: i 'f.N 10 miles wouid be esta:lisned for the plume exposure pa:nways and an cuter ::ne of abca:. 1/3k 50 miles would be estaclisnec for :ne ingestien ex:0sure ;a:nways. The precise si:e S.Q and sha:e of the E?Zs woulc be based on :ne judgemen of :ne emergency :lanner after c.i,4 considering local c:nditions. The Task For<e c:ncluced :na planning for m ceterminec $1; protective acticas, such as sneltering in the plume ex:osure :ene, is warranted wi-hin Q these enes in 'ne event of a sericus accident at a ;ower plant. The Task Fcrce also ippi rec:. ended time frames and radiological characteris-ics of :ne accicents for use in g%y. determining tne a:procria:e emergency '.ctions wnica c:uld be taken :: reduce ne accident consecuences. The Task Force concludec that if the basic planning elements - Wi in existing emergency planning guidance d cuments are already being c:nsidered, :ne $.6% ment emergency planning and preparedness costs. establisnment of E?Is shculd not result in large increases in 5: ate and local govern-9f I w(p,b 1 " T-
- 17. KEY WC ACS ANO OCCUMENT ANALYSIS 17a. CESCRIPTC AS
. j ;g f..Q ' t<. r.< j; wvu ,, ee 5 '.{ I 6 s e j N S i t ?.*,. ',_,> 7 &, e 3 G,
- r
~ ' - < ' S 17a. ICENTIPiE ASICPEN.ENCE O TE AMS m-R H> M. I y is.Ava:LAsiuTY STATEVENT
- 19. SE CU AiTY CLASS ITa.: resorts
- 1 NO OF # Aa
.(, Unli itCd . 1.' l C M.CE
- 20. SE CU 91 T v 0;. A55 Tos Js es L
~.c.c._,,,,,, M 1243 167 c v d I g W}}