ML19322E704
| ML19322E704 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/1979 |
| From: | Donaldson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19322E681 | List: |
| References | |
| ACRS-1704, NUDOCS 8004020141 | |
| Download: ML19322E704 (2) | |
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Oale I. Sc:aldsen, Radia:i== Specialis:
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?.I7:SID IMIRCNCT C*.ASSI.".CA!!CN STS "IM AND IMIR2NCY AC-~03' LI7E S Tci. NUC*IAR PC%T.R TAC 7 ~53 Ourt=g de M?J. I=argency ?la==i=g Task Force si:e visi:s := '"hree Mile Isla d and ?ilgri= 5:2:10: c Sep:e=ber 2a-27,1979, a dec=s== :1: led, "3 asis f== I=e:gency Ac=1:= Levels fer Nuclea: ?cus: Facili:ies" vas prsae::sd :o de li ensees.
(A copy of de dec -* # 's a : ached.)
he dcct=ss: vas ::ta:sd by an i=dividual in N?.?. and as::blishes a e=ergenc7 class'fi:2:10: sys:s= da: is subs:as:ially differes: f::= :he sys e=
ec=:2 :ed i= Regula:: 7 Guide 1.101.
Duri=g de hree Mile.tIsland 1
preses:2:10=, de docu=en: vas prese :sd as de acceptable classifica:1 =
sys:s= : be used, while a: Pilgri= t: vas prese=:sd as a cp:1c= :o be ::: side:ed.
7::s de :: e of the discussicus ud-" -'-=e Mile sland persc==el, i: appears da: dey will u:ilise the classifica:10: sys:e=
i= ace:: dance vid de guidance received by de Si:e Review Tea = Leade:
(Jack Roe).
here are several proble=s associated with de presen:atics of the doc.=:e== := licensees as well as sc=a basic proble=s vid de docu=es:
i:self.
~he revised classifica:1c= sche =a prese :sd i= de docu=e==
es:ablishes de fell::r.ri=g four classes of "s=ergencies:"
1.
Notifica:1== ci an unusual eve :
2.
Aler:
3.
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General Also included are exa=ples of emerge:c7 actics levels applicable :o each class. A review of this docu=e : i:dicates da: de revised sche =a does not es:ablish a " graded" systa= of classifica:10=.
he so:ifica:ics of an unusual even: class ties :=geder several :ypes of even:s under this class, rangi=g fr:= exceeding LCO's, LIR 's, Tech =ical Specifica:ie vtola: ices a:d i:e=s of "i=fc =atic=",
up :o ac:ua1 ave :s befcre elassified as Persecel, Local, Plas: (Unit) e=argencies.
The ce: effect has bes:
to le=p dree dis:isc: graded classes of t=ergencies i=:o c a ca:sge:y a10:3
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vi:5 events of a scu-e=erge:cy ca:ure.
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4 Each of de f:ur revised classes i clude securi:7 aspec s.
his see=s i=appr:pria:s
- s:.dering de fac: da: 73.f 3 and Appendix 3 :: 73.55 i: ::sfuncti:n vi h Sec=1:7 and ::::ingen 7 plans and preced=es al:mady add:sss.hese.ssues.
1: he ac uppe:
c'. asses of e=s:gencias, Si:s and ~,anera'., ders is an everla=, such da: de Gameral :spesse :s even:s da: =27 be of a Si:a e=erge= 7 a:=s.
Also of significa:cs is..ha: :he cc:141:a:i :s f :.he f eu: classes will be cade via l':s:see-NRC "het-lize."
This vill ::sats se=a very prac:1 cal proble=s for us.
Prese::ly, sc:1 fica:1:n of an u= usual ec:= ssen is =ade via "scr al" :alephc=e.
Subsecuss:ly,
- he Regica p spares a ?N.
Under de :svised sys:s=, de Headquar:::s
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.;a...3 have : he :: ass =1::ed :: :he Regi for"p spara:ics of e ?N.
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is :sasceable :: e:gec: da: de "he:-line" vill seen bece=s =crs
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- e. =_ ~ _ ~ ' =. ~..*.e. ev'. s e '. ' a s s ' _' '_.a. "...
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and could :ake away f::
de "=gse:" ca:=s of e=s gssc7 =ctifica: ices cade d: ugh de sa=e line.
Finally, c e of.he ebjectives f de Task Torte is :: eb ai
- sis:ss:
e=e:ge cy classiit:a-10: syste=s be: vee: :sspensible s:a:s ageneiss and de varicus : sac..:: lics:see's vidt: de state.
Sines de revised classifica:10 sche =a is being' preses:ed differe::17 by each Team Leader
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and a differe:: Team Laader vistis differs : si:ss vidi de sa=e sta:s, i: is possible da: ::e u:111:7 vill have de Reg. Guide 1.101 classi-fication :che=s while anc her u:ili:7 has de " revised'.' sche =e.
Apparse:ly :he :svised classifica:ics sche =e is also sc: :*ea: := licensees.
- hiring 6e si:s visi:s =any quesciens were :s' sed abcu: :he sens1:ivi:7 of de various leveis, y.any of dese questices vers sc: answered, leavi=g de licensee 's pla==s:s apprehensive.
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Dale I. Denaldscu
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[ O,i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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W A SM NGTON D O.
20460 s
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l Mr. 3rian Grimes Acting Assistant Director for Syste=s and Energy Division of Operating Reactors Nuclear Regulatory Co==ission
'4ashingten, D.C.
20555 Oear Brian:
I received a ecpy of proposed NUREG-0610, " Basis for E=ergency Action Levels for Nuclear Power Facilities," frc= Harold Collins with a request to forward our ce=ents to you.
I a= very pleased to see the NRC pursuing this type of approach which was suggested in =y letter to Bob Ryan of June 21, 1979 (copy enclosed). The concept of e=erter.cy action levels supports our guidance to the States which recc=end that they use infor=atien from licensees for early response decisiens.
I encourage this effort; however, we do have so=e questiens and reservations on the present proposal.
The supportive infor=ation to justify the relationship between the in plant status factors and the potential offsite scenarios is not presented in the =aterial we reviewed. I am sure that such a support docu=ent will be developed in the process of promulgating this guidance. We would like to review this =aterial before giving a'y final concurrence to a specific set of guidance.
'de have two specific criticisms of the present document.
W.e first is that, while we think it is appropriate to link ensite conditions to potential or projected offsite dose, we do not think it is appropriate to link onsite conditions with specific offsite protective actions. A good deal of judg=ent must be associated with protective actions at a particular site and a particular ti=e.
It would be 'oetter to acknowlege that these judg=ents are the prerogative of the States involved and to provide guidance for these judg=ents in documents that are directed to the States as opposed to l
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2 documents that are directed to licensees. On this basis we recommend deletion of the last sentence of the third paragraph on page 1.
We also recommend that the right-hand column of the action charts be relabeled as " State and/or local offsite authority actions which may be appropriate." This change will provide the licensee with some information regarding appropriate offsite actions but will not imply that he is responsible for taking these actions or that this document is directing the States to take these actions.
Our second criticism is that the " Site Emergency" is too severe to suit the title. The releases relate to potential doses in the range of 45 rem to the thyroid and 0 75 rem to the whole body at 1 kilometer downwind. These levels could justify offsite actions and, therefore, would represent more than a site emergency. What we are really suggesting is that the accidents which could justify offsite actions be divided into more classifications. For example, the " general emergency" should be further divided to indicate the release potential associated with each of the four conditions identified.
The changes that we are recommending would drastically change the document, and, therefore, it is not appropriate at this time to make detailed or editorial comments. We would be very pleased to work with you in developing a revised draft that would be more acceptable to EPA.
f Thank you for the opportunity to ce= ment.
Sincerely yours, F oyd L. Galpin Director Environmental Analysis Division Office of Radiation Programs ( ANR 461)
Enclosure
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(*D)i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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20460 JUN 211979 Hr. Robert G. Ryan Chairman, Federal Intaragency Central Coordinating Comittee (RERP)
Office of Stata Prograr:s U.S. t:ucicar Regulatery Ccmission Washington, D.C.
20:555
Dear Mr. Ryan:
In our preliminary review of the Three Mile Island Reactor Accident we notad r.u;r.erous itec.s that we believe recuire some follow-up action. P,any of these deal with the Environmental Protection Agency's (EPA) ovn response capability and we are procedding directly to carry these out. There are others, however, that are either diractly within the :urview of your t.gency or which may require cooperative efforts among agencies.
I am listing these recommendations here for your initial considoration. Ua would be pleased to partici-pate in a teeting with NRC staff representatives for more indepth discussions.
Several options were consider 4d ts to the appropriate way of bringing tuese concerns to the NRC's attention.
It was deciued that the most reasonaole course to follow war within the context of the Federal Interagency Central Coordinating Comittee (Radiological Emergency Preparedness), which yoit chair. As the EPA representative to that Comittee, I will also briefly present these concerns to the membership of the Comittee at the June 22 meeting.
Post Three !!ile Island Recormtendations for Nuclear Reculatory Cc=ission Consiceration 1.
More extensive T1.0 distribution around reactors should be considered as a part of approved offsite monitoring programs.
This would give a better basis for retrospective determination of impacts in the case of accidental airborne releases. Although the T1.D distri-bution at THI was abic to give an estimate of offsite exposures, it would have been helpful to have a more complete erea;.
TVA has been exploring this matter for some time at their Browns ferry facility.
2.
Effluent monitors in stacks, vents and other release points should be considered for dual ranges so that they are capable of quanti-tating accident level releases as well as routine releases.
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3.
The hard-wiring of some measurements of reactor parameters i
and release conitors to NRC should be considered.
This misnt be I
either to the Regional Office or NRC Headquarters. Such considera-tion should include evaluation of benefits, costs, potential for added confusion and reliability.
j 4.
There apocars to have been an inadequacy in instrumentation in containcent that was haraened to withstand an accident envircament 1i An evaluation of tnis should be perfomed.
As all of our guicance I
to States has ic;: lied a first order dependence on the facility I
operator for informaticn on releases, we must be assured that i
l Instrumentation is adequate for this purpose.
I 5.
Incrcased considuation should be given to exploring the possibility of devising appropriate control room scenarios, as daternined from instrument readings, that could be the initiators to emergency actions and offsite notifications. This matter has previously been discussed with Dr. Ian Wall and Mr. Roger Blond of -
the hRC nuclear Regulatory Research Program, who indicated that they had been examining this possibility.
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6.
An issus that is sure to be raised is whether NRC concurrence in a Stata c:ncreency response plan should have any influence on tha j
licensing of facilities in that State.
We reali:e that this would be a major departure from past practica and may not have cn adequate legislative basis at present.
Our concern with this mattar is i
primarily asscciated with the relatdd issue of fincing for State emergency I
planning, and the specific relationship of plan testing to HRC concurrence.
This general subject area is also raised in the recent report. "beyond Defense-in-Depth," by Stephen H. Salomon of the NRC's Office of State Progracs.
7.
A plan for improving the coordination of Federal agency response is needed if we assuma that in the case of a significant nuclear facility accident, suen as Three Mila. Island, the various Federal agencies with responsibilities in the area of radiation protection will feel obligated to initiate their own response.
It does not appear that the prese.
II<AP tc. mat fulfills the total need.
Also, such Federal responsa should be conductmi and coordinated in such a manndr as to not place any further administrative burden on the State, I
while at tha sama time providing those responsible for decision-making and public assuranca with the maximum of useful informacion.
Therefore, such a plan for coordination of Federal response should not only cover technical response, i.e., radiation measurements, bue logistical and l
comuntcations support.
6 The THI indident pointed out that tne -
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Kitsap County G
Department of Emergency Services m omSioN sr (ITSAP COUNTY COURTHOUSE
- PQRT oRCHARo. WASHINGTON 95364
- TELEP**oNE (208) 576-6077 31 October 197,c Mr. Brian K.
Grimes Act1ng Assistant Director of Systems Engineering Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington D.
C.
20555 Following are my comments on your Memo dated September 17, 1979 "3 asis for Emergency Action Levels for Nuclear Power Facilities".
Nctif1:ation of Unusual Event In our case we are dealing not with a power reactor operated by a private utility but with a Department of Defense Installation (U. S. Navy).
First of all there is the matter of Military Security.
Is it necessary or even wise to require or request a Military In-sta11ation to report to outside Agencies any and all small irregul-arities or malfunctions which may be immediately correctable while backup systems are functioning properly and there is no indication of a present er imminent danger arising?
Fire,or Security is Lm- -
mediately available on the Installation.
gjpgr,fi If such a requirement is mandated I believe it should only be in the form of a communications check with the Local Response Lead Agency and require only a verbal closecut.
Alert As with the previous class the Military Installation has its own Fire Fighting and Security capabilities which weuld be augmented by off-site agencies only during extreme emergency conditions.
Because we are deding w_th a Military Installation I believe it appropriate that the summary be oral only and limited to the Lead Of f-site Agency.
Site Emergency This class and the General Emergency Class plainly cover a situation which calls for an off-site response.
However, because both classes cover such a situation why not have just one class ca11ed Emergency, making a total of 3 rather than 4 classes?
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Supoortee by the Kitsao County Emergency Services CounciY 91106 0 h/jf f'
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3 preplanning for coordinating a multiple Federal agency response has not been giYen adecuata consideration.
Fortunately, due to the
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efforts of the Departmant of Energy (00E) and the general coopera-tiveness of all of tne agency conitoring teams, the response coordination was quickly pulled together. Such an ad hoc approach should not ba depended upon, however.
8.
Relative to HRC concurrence with State emergency radiological response plans, me need to evaluate how we can assure that the various Statt agencies and their decision-making Administrators are adeouately l
1 infomed of the plaa so that they will act in concert with it rather than on the basis of their perception of their responsibility at the moment. This should include an examination as to the adequacy of the detail in describing tho channels of comunication and advice that the responsible decision-makers will depend on for initiating actions.
9.
It is unclear as to the internal procedures and criteria l
that NRC follows in fomulating its advice for States on the advisa-I bility of protective actions to ba taken. During the course of an incident, sucn advice will be called for, and it should be prepared t
in scac pre-organized manner witn predetemined responsibilitics rather i
tnan evolve on an ad hoc basis. There may be otner Federal agencies that tiMC sitould involve in this. process and EPA would certainly be willing to assist. On the otner hand, the advice giving precess must be simple, unencur. cered, and nopefully, witia a single point of contact with responsible State decision-r.akers.
10.
I He understand that the Livermore ARAC system was extensively used during the THI incident. We would like to have tiRC evaluate its offectiveness and the possibility of a tie-in with AGC.for each nuclear power facility.
If its use is desirable, consideration should also be given to involving ARAC in facility emergency plan tests so that the operators can gain experience as to how this resource can be best utilized.
Sincerel'y yours.
EEd. Floyd L. Gd;a:
Floyd L. Galpin Director Environmental Analysis Division Office of Radiation Programs (ANR-461) cc: David G. Hawkins, AA-ANR (ANR-443)
Stephen J. Gage AA-R&D (RD-672) 4 k i
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l In all cases and at:b all classes : believe a becter Liscing of Terms is needed to indicate to the Off-Site Lead Agency just what is happening and just what :he danger is or =ay develop to be.
Again : question the necessity er propriety of demanding a written su= mary frc= a Military Installation.
- believe verbal su:::=ary to the Lead Of f-site Agency should suffice.
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'Lelaud J. Daly Director LJD:mpd c.c. James Montgomery l
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EMIL GARRETT Lt; Col USA Ret.
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