ML19323C932
| ML19323C932 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/12/1980 |
| From: | Walbridge W SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Pagano F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19323C933 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 TAC-46265, NUDOCS 8005190427 | |
| Download: ML19323C932 (6) | |
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80 0510 0 yp 7 g SaluD SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S street, Box 15830, sacramento, California 95813; (916) 452-3211 May 12, 1980 Director of Nuclear Reactor Regulation Emerge'cy Planning Review Team Leader U. S. Nuclear Regulatory Ccmmission Washington, D. C.
20555 Attn: Mr. Frank Pagano Docket No. 50-312 - Regulatory Guide 1.101 Emergency Planning for Nuclear Power Plants Rancho Seco Nuclear Generating Station Unit No.1 Gentlemen:
The revised draft Rancho Seco Emerg icy Plan has been updated following your April 2, 1980 letter. To meet me five week deadline, t;e are sending the draft before internal review by the Plant Review Committee and the Management Safety Review Committee. Any resulting modifications will be promptly forwarded.
The draft Emergency Plan was written before the issuance of the criteria in hDREG-0654 FEMA-REP-1 and reviewed while the criteria were in their initial stages of public comment. There are many unresolved questions associated with these draft criteria. Evaluation of the Rancho Seco Emergency Plan against every item in the draft is inappropriate until these questions are answered.
Emergency Plans should be "living documents" in that they should evolve as drills uncover needs for improvement.
Plans should also be workable and not just be able to satisfy a list of requirements. The revised draft Rancho Seco Emergency Plan is a good plan.
In our opinion, it satisfies the intent of HUREG-0654, is flexible, workable, and provides safety to the public with a wide margin of safety. The following comments OYy clarify our position on particular items.
Comments b
NUREG-0654 Table 4-3 provides curreqt estimates of manpower andN FEMA-REP-1 response times for Rancho Seco staff, and are felt B-5 (Table B-1) to be realistic and appropriate.
It is my under-2d2 standing that the 30-minute criteria is for high LEM population density sites only. Rancho Seco is an h 6 ( ;C isolated and low population site.
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E?B doe THIS D0uMENT CONTAINS Sa d; 3
g POOR QUAI.lTY PAGES g
Mr. Frank Pagano May 12, 1980 Comments (continued)
C-2 Responsible individuals from each governmental emergency operations group will be at the offsite Emergency Opera-tions Facility. These individuals would be involved in the offsite environmental data analysis, recommendations and response decisions, and will be able to direct their people from our EOF. Sacramento, Amador, and San Joaquin County emergency groups and the State emergency group and SMUD believe this is a waste of manpower and an unnecessary duplication of effort.
H-6b A minimum of 40 TLD stations will be in position around Rancho Seco by July 1, 1980 in compliance with the NRC Radiological Assessment Branch Technical Position for the Environmental Radiological Monitoring Program. Agreements are in progress to obtain easement rights to private land to the north, east, and south of Rancho Seco. Meetings are in progress to duplicate five locations with the NRC Region V and the State of California. Details will be provided when the project is complete.
H-8 (Appendix 2)
Comments provided in enclosure.
1-5 Meteorological data is available to all locations via telephone. Computer data transfer will be available July 1981.
I-7 A detection capability of 5X10-8 uCi/cc is an unreasonable request for emergency response measurements. A value of 10-6 uCi/cc would be much more realistic and attainable.
J-10a Sacramento County Emergency Operations Office is preparing these maps. They will be completed in June 1980. SMUD will distribute copies to the Technical Support Center, Onsite Emergency Operations Center, and the Offsite Emer-gency Operations Facility.
J-10b Sacramento County Emergency Operations Office is updating the population distribution around Rancho Seco in five mile increments for the 16 sectors. The one mile incre-ments. from 0-10 miles is unre asonable and provides unneces-sary detail for the emergency situation.
J-10c SMUD is working with the Sacramento County Emergency Operations Office and FEMA in researching the most appro-priate way of notifying the public in the vicinity of Rancho Seco. Much progress has been made on the project.
Completion should be well in advance of the July 1981 deadline.
Mr. Frank Pagano May 12, 1980 If you have any questions concerr'ng the revised plan or the aboVe ConEents, please contact either Don Martin or Edward Bradley on (916) 452-3211, ext. 603.
Sincerely, Wm. C. Walbridge General Manager Enclosure 0
SACRAMENTO MUNICIPAL UTILITY DISTRICT COMMENTS REGARDING NUREG-0654 APPENDIX 2 NUREG-0654 Appendix 2 sets new requirements to ensure that valid meteorological data is available at nuclear power plants before and during accidents involving radioactive releases to the atmosphere. The primary aspects of NUREG-0654 Appendix 2 are:
Meteorological Tower
- Sufficient well maintained instrumentation Reauncant power supplies Primary Acauisition System Redundant power supplies
- Real-time data acquisition and display
- Historical, accessible cata files in 15 minute averages for the previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Ability to project dispersion f actors out to 50 miles for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance Ability to be remotely interrogated Backup System
- Must be on-line within 5 minutes of primary system f ailure Must supply basic meteorological parameters O stability class via delta-T or wind direction fluctuations 0 wind speed 0 wind direction Quality Assurance Ensure accu"acy and reliability of systems To bring Rancho Seco's present system into compliance would involve several changes and purchases probably exceeding $250,000 total cost. These changes include:
Meteorological Tower Add precipitation gauge, may cost several hundred collars.
Change procedures to ensure that only one of redundant delta-T's, wina speeas and wind directions is out of service at one time.
- Move relative humidity instrument from 6' (1.8 meter) to 33' (10 meter) level and calculate dew point from r.h.
Have one 33' level sensor reaa out temperature as well as input to delta-T.
Provice redundant power supply via battery backup or by tying existing power source (administration building motor control center) to redundant power supply. Reaundant power for the tower could cost over S30,000.
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c Primary Acquisition System Purchase new data acquisition computer having abilities to meet the NUREG requirements.
O real-time data acquisition and aisplay 0 historical data files O projection abilities O remote interrogation ab'ilities Consider integrating offsite dose calculations with this unit since the same meteorological data files are used in both cases.
Total computer costs will run between $100,000 and $200,000 depending on wnich job functions are included.
Provice redundant power supply, can probably be done for under
$10,000.
If tied off Bailey 855 reaundant power can probably be supplied for less than $5000 although this power supply may not have the excess capacity required by the new computer.
Backup System Use existing acquisition system in whole or in part to provide the backup system.
O reprogram NOVA for 15 minute averages O moaify multipoint recorder to allow manual switching from A to B sensor if A sensor fails.
Keep backup on-line continuously or proviae auto start upon primary system failure (on-line is easiest).
Provide recundant power supply.
Quality Assurance Upaate Quality Assurance procedures to account for any new equipment or procedures.
NUREG-0654 is currently out for interim use and comment. While we have listed the requirements to comply with NUREG-0654 Appendix 2 it is our opinion that not every detail is necessary. We have the following comments:
Meteorological Tower NUREG-0654 does not state anything about backup towers although verbal contacts with the NRC has indicated a desire for at least a " wood pole" backup. Rancho Seco currently has reaundant delta-T, wind speed and wind direction on the same tower. Any incident likely to cause tower failure along with a radioactive plant release is more than likely to a.so cause failure of the wood pole. Any incident that could fail the primary tower (e.g. Vehicle collision) and not affect the " wood pole" is also unlikely to cause power plant damage with a radioactive release. We do not think a backup tower or pole is necessary if the main tower has redundant instruments and a redundant power supply.
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Additionally, we feel that if we already have temperature indication and relative humidity at 1.8 meters (6') it should not be necessary to move these to 10 meters as required by NUREG-0654 Also, since we have relative humidity already it should be acceptable in lieu of dew point.
Primary Acauisition System NUREG-0654 requires radiological projections out to 50 miles distance. This can be done with existing on-the-market systems using Gaussian models. The validity of projecting out to this distance with Gaussian is highly questionable. We feel that Gaussian projections should be limited to 10 miles.and that NRC work with DOE to make the only known system capable of realistic projections compatible with and available to nuclear power plants (i.e., Atmospheric Release Advisory CapaDility (ARAC), at Lawrence Livermore Laboratory).
ARAC has capability of using complex models that are much more valid at distances up to 50 miles.
Appendix 2 to NUREG-0654 requires that the primary system have a dial up connection with a functional backup.
It cites radio or satellite as examples. The costs and frequency problems would be enormous. Dedicated phone lines or microwave should be sufficient.
Backup System It has been assumed that the backup system should provide basic data:
wind speed wind direction stability category by either:
O delta-T or 0 sigma-theta It is also assumed that communication of this data would be by reading data over the phone. Hand calculations could be used to determine diffusion factors offsite. These equations are being included in the 0654 upgraded Emergency Plan.
To require anything more from the backup system would rapidly drive up costs and take up room with additional equipment to backup equipment that would already have high reliability due to redundant instruments and redundant power supplies.
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