ML19260C379
| ML19260C379 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1979 |
| From: | Collins H NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Lafleur J NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| References | |
| NUDOCS 7912260263 | |
| Download: ML19260C379 (7) | |
Text
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d UNITED STATES y,..%'g NUCLEAR REGULAIORY COMMISSION 1
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NOV 2 71979 MEMORANDUM FOR: Dr. Joseph D. Lafleur, Assistant Director for International Cooperation Office of international Programs FROM:
Harold E. Collins, Assistant Director for Emergency Preparedness Office of State Programs
SUBJECT:
COMMENTS ON FRENCH EMERGENCY PLANNING DOCUMENTS Attached are the comments on the French Emergency Planning documents requested by General Marchand, the Director of French Civil Defense.
Harold E. Collins Assistant Director for Emergency Preparedness Office of State Programs
Attachment:
As stated cc: RGRyan, SP 1617 262 7912 60 263 2
i l
l During a recent post-TMI visit by General R. Marchand, Director of French Civil Defense, he requested that NRC review and comment on seVeral French emergency planning documents. Mr. Harold E. Collins, Assistant Director for Emergency Preparedness, NRC Office of State Programs, has reviewed these documents and offers the following comments.
Mr. Collins' comments are his own, based on his years of experience in this field. They do not necessarily reflect the views of the Nuclear Regulatory Commission itself.
The following documents were received from General Marchand:
1.
" Recommendations pour la Preparation et la mise en oeuvre des mesures de Protection des Populations au Voisinage des centrales Electronucleaires en Case d' Incidents d' accidents Pouvant Comporter Eventuellment des consequences Radiologiques".
(NRC Translation 590:
"Reconmendations for the Preparation ard Implementation of Measures for Protecting Populations in the Vicinity of Electronuclear Power Plants in the Event of Malfunctions or Accidents which could Eventually Include Radiological Consequences".
2.
NRC Translation 589:
" Release Testing", C 160 Transall-DC CL 215, Prefecture Des Bouches - Du - Rhone, Valabre Test Center.
3.
NRC Translation 591:
" Utilization of DC-6 Aircraft for Firefighting", UTA Industries, GIE/DP Development Industries.
NOTE:
Copies of all English language translations are enclosed.
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COMMENTARY ON DOCUMENT N0. 1, I
NRC Translation No. 590 NOTE: The coments that follow, where indicated, refer to the page numbers on the NRC English language translation.
A.
General Comments:
Impressions of the intent and content of this document may suffer slightly from our English translation of it.
However, the " Foreword" of the document (page 2), generally indicates that it is published as some sort of guide for "special operational plans" supportive of a plan whose acronym is ORSECRAD, which is classified by the French government and cannot be released according to what is said in the " FOREWORD".
Be that as it may, and without having knowledge of the concepts of the ORSECRAD plan, one can make a few general observations about this particular supporting document to ORSECRAD.
In general, I find that this document encompasses some of (but not all of) what we call " essential planning elements" for offsite radiological emergency response plans in the U.S.
The concept of " alert levels," and countermeasures (protective measures in the U.S.) seems to be acknowledged.
Resources, Command Structure and Cartography are acknowledged in the document, as important essential elements in planning.
There may be, and obviously are, other supporting emergency planning documents, namely the ORSECRAD, which contain more of the important essential emergency planning elements that we have developed in our U.S. guidance documents. This particular document (NRC translation no. 590) does not definitively address all of the essential elements that we are familiar with in the U.S..
Many of the essential planning elements that we have identified in our primary guidance document for U.S. States and local governments, (NUREG-75/111, Reference 1) are missing from this French document, or not discussed in enough detail to be useful to the recipients of the document.
One of the major criticisms I have of this document, is that it appears to be defensive of the safety of nuclear power plants and perhaps a bit too promotional.
It emphasizes an " infinitesimal" probability of serious accidents and almost apologetically sends the message that emergency plans are necessary, but grudgingly so.
This attitude would never be supported in the U.S. i.cday.
It may be different in France.
But if the serious intention of this document is to provide guidance for the development of "special operational plans" at local government levels, it falls below the mark for guidance established in the U.S.
If it were a U.S. document, it would raise more questions than it answers and would, I'm sure, be severely criticized for inadequacy by local and State government authorities, based upon our experience with guidance documents.
Trying to put myself in the position of a local government official (in France or in the U.S.), and armed with this document and charged to produce an emergency plan, I would be hard-pressed to know what precisely was required af me.
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,h The major strength of the document seems to be organizational in that the document does recount several levels of responsibility and resources, right up to the national level in France.
Finally, as a general comment, the document is not specific enough and mainly deals in generalities.
Here again, since this is a single document and any other existing documents have not been offered or reviewed, the commentary is limited to this one document.
It is not as specific or useful as emergency planning guidance documents produced in the U.S. (see copies of enclosed U.S. guidance documents, References 1, 2 and 3).
B.
Specific Comments:
1.
Page 5 (of NRC translation no. 590).
At the top of the page, is an example of a defensive attitude in terms of probability and consequences as these terms relate to emergency planning and preparedness.
Expressing this notion too strongly, may in itself defeat the purpose of the document, which ought to say clearly, that emergency plans are in fact prudent and necessary.
2.
Page 6, 3rd paragraph.
We support the notion of a real time accident assessment /information system (see enclosed publication on U.S. Lawrence Livermore Laboratories Atmospheric Release Advisory Capability (ARAC) (reference 4).
3.
Page 8, paragraph B-4.
We support " canned" prepared messages concerning emergencies, as long as there is room to " fill-in-the-blanks" with accurate, unequivocal information at the time of the accident.
4.
Page 10 etc., Section A, " Alert Levels".
We support the concept of " Alert Levels" (called " Emergency Action Levels" in the U.S.).
However, the " Alert Levels" in this document are perhaps fractionated to an excessive degree with " Conventional Alpha and Bravo" and "Inside Alpha and Bravo".
(See reference 5, U.S.
NRC NUREG-0610 for U.S. approach.)
5.
Page 19, Section B " Methods for Protecting Populations".
We support the concept of "immediate notification" of offsite authorities and the concept of close coordination of onsite and offsite plans.
(This has been a weak point in U.S. plans.) The words on this page about panic and its attendant difficulties, although possible, do not seem to be a major consideration (based on U.S. experiences), as long as information and communication systems are adequate.
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6.
Page 20, Section B.
The discussion downplaying evacuation as a valid protective measure, is not one that we can support.
As a matter of fact, evacuation may have to be implemented under some circumstances close in to the plant (see reference 6, NUREG-0396/ EPA 520/1-78-016).
Because of meandering meteorological situations, evacuation may have to be implemented in an area, close to the plant, in a 3600 area, either on a precautionary basis, or based upon rapid accident assessment.
Sheltering as a protective measure is valid only if the shelters are adequate in terms of airtightness and sound construction.
Here again, except for brief
" puff" type radiological releases, there are long term problems with sheltering which, if the radioactive release persists, may dictate evacuation as the ultimate protective measure.
7.
Page 20, next to last paragraph.
We do not agree with the concept that several hours would be available in all cases, for implementing protective measures (see reference 6).
8.
Page 22, Section C, " Resources" We support the concept of having a technical group of advisors to be on-call and on-hand, at all times, including backup personnel in case of absences of primary advisors.
9.
Page 26.
The discussion concerning First and Second Echelon Control Zones (ZIDE),
is not precisely clear.
It is not clear as to whether these are
" administrative geographical zones" of the French Atomic Energy Commission, or emergency planning or preparedness zones around each nuclear facility. The latter concept, which is being established in the U.S.,
Switzerland, and the Federal Republic of Germany, is the concept that seems to be valid, to support individual nuclear facilities.
(See reference 6.)
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4
. s
- COMMENTARYONDOCUMENTSNOS.2AND3(NRCTRANSLATIONS589AND591)
I l
A.
General Comments:
These documents are documents based on U.S. documents concerning utilization of aircraft for firefighting purposes, namely water and chemical releases to control fires.
I assume that these documents were sent to us because of a possible French plan to utilize airborne firefighting techniques in the event of an airborne re' ease of radioactive materials from a nuclear facility.
There is no question that if a radioactive material release occurred from a nuclear power or fuel reprocessing or manufacturing facility, in a rainstorm, that the effects of precipitation would increase the rate of " plate-out" or deposit'on of radioactive garticulate material on environmental surfaces.
Under proper meteorological conditions, this increased rate of deposition (or " plate-out"), could result in reducing deposition in areas farther from the site of the accident but at the same time, increase the total deposition close-in to the site.
However, the notion of using aircraft to drop large quantities of scavenging chemicals and water, on the site of a nuclear facility accident, or in the surrounding en, irons, has never been considered (in a serious sense) to my knowledge in tb U.S. or elsewhere.
But, this is not to say that such a concept or noti _1 might not be useful under certain circumstances.
But, it would seem to na, that the radioactive release would have to be of relatively catastrophic proportion in order for this concept to be of some validity, and further, the radioactive release would have to contain particulates, not only gaseous products.
In general, no such use of aircraft to drop chemicals and water in the environs of nuclear power plants, in the event of an accident, has been envisioned in the U.S.
B.
Specific Comments:
We have no specific comments.
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1, REFERENCES 1.
Guide and Checklist for Development and Evaluation of State and Local Government Radiological Emergency Response Plans in Support of Fixed Nuclear Facilities (NUREG-75/111).
2.
Emergency Planning for Nuclear Power Plants (REGULATORY GUIDE 1.101).
3.
Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA-520/1-75-001).
4.
A Study of Applying the Atmospheric Release Advisory Capability to Nuclear Power Plants (UCRL-52525) - ARAC Update-1979 (UCRL-52802).
5.
Federal Register flotice of September 26, 1979 Concerning Draft Emergency Action Level Guidelines for Nuclear Power Plants (NUREG-0610).
6.
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).
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