ML19323C943
| ML19323C943 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/13/1980 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Ryan R Federal Emergency Management Agency |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8005190447 | |
| Download: ML19323C943 (20) | |
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8006.190447 BALTIMORE GAS AND ELECTRIC COMPANY P. O. B OX 1475 B A LTIM O R E, M ARYLAN D 21203 May 13, 1980 ARTHUR C. LUN OVA LL.JR.
vice Pmgseote t s
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?!r Robert G. Ryan Director, Radiological Frer.~ency Preraredness Division Federal hernency !!anagement Acency 17P5 I Street N.*l.
Uanhington. D. C.
20L72 Docket Nos.
50-317 50-318 License !!os. DPR-53
Dear Mr. Ryan:
DPR-69 During a recent meeting with the NRC Ihergency Review Team assirned to the Calvert Clif*'s nuclear Fover Plant, it was made quite clear that any comments ve night have regarding the IIRC's current requirements on emergenc~ clanning should be transmitted formally.
At this meeting, the NRC/F CA team emchasized that their requirements were those srecified in
?!UREG 065h/FF1'A REP 1 vith little or no deviance.
Accordingly, 'altinore Gas and Electric is oroviding the enclosed detailed comments on NURIA 065h/FEI'A-REP-1 which we consider to be resnonsive to all outstanding NRC/FE!A requests for contents on radiological emergency planning issues raised at the necting.
In providing these comments, we vish to note our acreement with the ob.iective of improved emergency planning for nuclear facilities and our belief that the enclosed ccements are consis-tent with that objective. We particularly wish to notc that where the proposed NRC/FD'A requirements are inconsistent with the wishes or capabilities of our local and state officials, the nost careful attention should be given to the reconnendations of those officials, who bear the majority of the responsibility for interfacing with the citizens in the plant's vicinity.
Very truly yours,
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Enclosure cc: Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attn: Docketing and Service Branch General George Brochs, Dir., !!aryland CD & DPA k
Messrs. R. E. Corcoran. Div. RAD Control State DBUI
\\
V. D. Hors =on, Civil Definse Director, Calvert County
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O. Wood, Civil Defense Director, St. !!arv's County O. B. Chessman, Jr., Civil. Defense Director, Dorchester Co.
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- ]D f c o M e Mull o
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Fobert G. Ryan May 13, 1980 cc: Messrs. R. B. !!inogue, U. S. f!nclear Regulatory Co mission II. R. Denton, Director. Office of !Iuclear Reactor Regulation E. L. Conner. Jr., U. S. !iuclear Reculatory Co m ission I
COZ4ENTS OF BAL"'IMORE GAS AND ELECIRIC COMPAITY ON COMBINED NUCLEAR REGULATORY C0Z4ISSION/FTDERAL EERGENCY MANAGECNT AGENCY'S
" CRITERIA FOR PP2PARATION AND EVALUATION OF RADIOLOGICAL EERGENCY RESPONSE PLAUS AND PREPAPIDNESS IN SUPPORT OF NUCLEAR P0iJER PLANTS" (FOR INTERIM USE AND COMENT)
HUREG-065h/ FEMA-PIP-1 INTRODUCTION In general, NUP2G 065h/FD4A-RIP-1 (hereinafter referred to as NUREG 065h) is a useful effort at delineating the latest thinking by NRC and FEMA on radiological recponse planning for nuclear power plants ; however, there are a number of areas wher-the documents inflexibility precludes acceptable and locally preferable alternative solutions. Also, the document suffers in places from the failure to separate the function of protecting the public from the function of infor=ing the public (pri=arily through the media). Finally, the document and its interpretation lacks necessary integration, appearing in places to represent the thinking of individuals or groups within the larger organizations.
It is stated (p. h) that " FEMA and NRC regard all the elements contained here as essential for an adequate radiological emergency plan." The elements are then stated to include notification, em mications, public infomation, equipment, accident assessment, exercises, and drills. It is useful and helpful to have the NRC and FE4A issue, in NUREG 065h, a catalog of the capabilities and procedures they intend to use in evaluating emergency planning efforts. However, most of the specific requirements represent only one of several alternative means of assuring that a high degree of emergency preparedness is developed and maintained. In fact, many of the criteria in NUREG 065h represent new staff positions - developed just in the last few months. They have not been subjected to peer review or documentation and, as subsequent comments indicate, many deserve some reconsiderat-ion and revision. Since the NRC/ FEMA team site visits have already shown that NUPSG 065h is being used as an inflexible checklist, necessary revisions to that docu=ent should be issued as quickly as possible.
Paga 2 7nere are three specific concerns that warrant special attention:
- 1) The 15 minute notification requirement (and corresponding criteria for mobilization of support personnel, sirens / tone alerts, etc.) is based on an inconsistent pre =ise and should be revised. Credible accidents that can lead to a very large release of fission products to the environment, sufficient to require protective actions out to 10 miles are slow to develop - a day or more from onset to significant release are much more likely outcomes of these very i= probable events than a release within an hour or two.
Consequently there vill be time for an orderly process of notification. In the highly unlikely event of a more rapid release, varnings vould be li=ited to specific wind selectors, and concentration of emergency resources vould prove more efficient than general approaches over all sectors. For the specific geography and demography of Calvert Cliffs, this is particularly true.
- 2) The presumptive or precautionary nature of the criteria - where a site or general emergency condition must be declared based on process instrumentation well before the assurance of any significant release to the environment occurs.
In view of the strict notification requirements it is better to couple the public notification / protective action process to actual releases from the plant or projected doses which can reasonably be expected rather than on the basis of plant conditions which, if uncorrected, might ultimately lead to a 41 ease.
- 3) There are a number of requirements which are only peripherally related to e=crgency preparedness yet which are written (or interpreted) with such specificity as to seriously hamper the legitimate judgmental process of the state and local officials and the plant operators. The arbitrary requirement for a relocation center at least 15 miles from the plant, a principal Emergency Operation Facility
Pago 3 (EOF) within one =ile of the reactor, and a redundant and exotic meteorological data system are cases in point.
As a final general comment, it should be noted that NUEG 065k/ FEMA-FIP-1 refers i
to 32 other documents, many of which provide supplemental criteria that are to be followed. Requirements which arise by reference to such documents should be avoided; vnere necessary, relevant guidelines should be extracted from such reports and included in the next version of NUEG 065h. References to docu ents still in the comment stage, such as !;UREG-0610, should be avoided.
i l
Specific Ravisions to UUREG 065h Evaluttien Critoria II.S.5 Revise last sentence to read: "The mini m capabilities and staffing enshift and/or available following the declaration of a site emergency or general emergency shall be as indicated in Table 3-1."
3 asis:
(1) Given the for-cos: ment status of Table B-1 the reference to minutes should be relegated to the Table: (2) For events of the type listed in h"JRIG 0610, only those in the Site and General Energency classes nor= ally varrant augmentation of plant staff; (3) Different levels of augnentation may be appropriate.
II.3.5 Revise requirement for "HP Technician" or " Rad / Chem Technician" on Table B-1 Shift.
Basis: Assuming the major tasks involved are based on NUREG-0576's Improved Post-Accident Sampling capability requirements, it is redundant and unnecessa:y to have two individuals on shift to perfom these functions prior to augmentation of the emergency organization. One of either type of expertise should suffice in meeting the requirement.
II.B.5 Re%se extreme right column heading to read: " Additions Within Table B-1 Approximately 60 Minutes."
Basis: Unrealistic augmentation tine considering that most plant personnel reside outside a 5 mile radius of nuclear plants. Augmentation of plant staff should be planned to allow finite time for notification, den clothing and travel to the plant. A reasonable augmentation time vould be approximately 60 =inutes recognizing that many personnel vill j
arrive within 30 to h5 minutes depending upon where they reside.
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Paga 2 II.B.5 Delete " Shift Foreman."
Table B-1 Notes:*
Basis: The Shift foreman vill be in the crew of the affected unit assuming no problem occurs with unaffected unit. The Shift Supervisor or Shift Foreman on affected unit vill supply coverage, if in the unlikely event SRO coverage is needed before the second Shift Foreman arrives as part of the augmenting crew.
I II.C.2 Delete the second sentence.
Basis: The other requirements in NUREG 065h provide for an extensive com=unications netverk, which vill join representatives 1
l from all " principal organizations" (a term which deserves clarification).
The requirement to send utility staff to governmental centers vill increase the risk that such centers will not rely on the EOF, vill divert needed resources from the plant, and is unlikely to ar*i7t the actual task at hand.
II.D.1 Revise first sentence to read:
"An emergency classification and emergency action level scheme si=ilar to that set !Jrth in NUREG-0610.."
Basis:
NUREG-0610's emergency classification includes an unusual events category which consists of non-emergency conditions that may be reportable because of their current newsworthiness and public interest nature. State and/or local offrit: aa!horities should be notified of those events by procedural requirements outside emergency planning similar to that required by a recent NRC rule-making (10 CFR Part 50.72).
Pag 2 3 II.D.2 Delete.
Basis : (1) This criterion is redundant in as much as D.1 requires an organization of the spectru= of events into four classes and identification of these conditions which are indicative of each class.
(2) As noted on Page 5, "No single specific accident sequence should be isolated as the one for which to plan because each accident could have different consequences, both in nature and degree." This logic suggests that the exanples of NUREG 0610 should remain just that and preferably that reference to specific initiating events be eliminated and replaced by specific plant parameters and/or projected doses.
II.D.3 Add "Should this schene be different from that set forth in NURIG 0610, the emergency plans of each or6anization shall reflect the agreenent to use a modified scheme, and that modified scheme shall be used consistently."
Basis: (1) This criterion is apparently intend.ed to avoid nonstandard criteria and nomenclature, which may mean different things to the utility, the state and the local officials.
- ihile this is an important v
objective, the lang"9ge of II.D.1 invokes an impossible situation where l
compliance with NUPIG 0610 is the only permitted vay to achieve uniformity of practice. It is possible that state and local authorities may vish the utility to use their existing scheme.
II.Z.1 Delete " set forth in NUREG 0610." Add the word % sed."
Basis:
Same basis as II.D.3.
1
Paga h II.E.6 Delete "(see Appendix 3)."
Basis:
(1) This parenthetical phrase incorporates, by reference, a set of imple=enting criteria which have been the source of considerable controversy and debate. It would be preferable to separate the detailed and still evolving implementing criteria from the more general criteria of II.E.6.
II.E.6 Delete last two sentences. Add:
"It shall be the responsibility of the State and local governments to ensure that such means exist and to activate suc' syste=s."
Basis:
It is clearly the responsibility of the State and local governments for installation of notifications systems to the public.
If this proposed requirement is based on concern for funds, these should be furnished by FEMA or other governmental agencies. It is expected that the notification system vill be used to notify the public-of other emergencies (tornado, flooding, chemical threat, etc.) besides radiological threat. There is no constitutional justification for a tax paying corporation to be subject to additional assessments to
+"
Paga 5 provide a service which is nor= ally the responsibility of a govern-mental agency, -
fire protection, police protection, etc.
II.E.6 Delete " Applicability" under operator.
Basis : Same basis as II, previous page.
II.E.7 Delete " applicability" under operator and add it to local.
Basis: The criterion applies only to the groups which are to notiP/ the public as to actions to be taken.
II.E.7 Delete second sentence.
Basis: The accidents within any given category would result in videly varying public consequences. Some would not result in a release for a day or more some vould result in a release within an hour.
As noted in NUREG 0610 (see Note to item 2, page 1-13),
the messages to the public vill depend substantially on the specific circumstances, and sheuld not be formally predetermined.
II.G.1 Delete " Applicability" under Operator.
Basis : This responsibility should lie with the State and local governments, not the utility. Utility should provide recommended information to the State and local gove:nments, if requested.
Separate dissemination may lead to inconsistencies in infomation provided, possibly creating confusion or lack of confidence among the public.
1
Pago 6 II.H.2 Delete second sentence, Basis :
- he utility, local, and state agencies should be permitted to deter =ine their facility / interface needs en an individual bases, rather tha=-
being forced to meet some arbitrary requirements which do not take cognizance of existing facilities and equipment.
II.H.3 Insert the word " principal" before the word " organization."
Basis: It is unlikely that each group providing support vill require a separately identified facility for nuclear emer gencies.
II.E.5 Replace ":rDREG 0610" by the words, " emergency action level scheme."
3 asis : This criterion is a duplication of an expansion on II.D.1.
""ne principal objective should be to assure a direct link between recorded levels of plant conditions and predetermined levels that call for some type of emergency actions. Thus the better reference is EAL's and not NUREG 0610.
Pag 2 7 II.H.6 Revise to read, "Each operator shall make provision to acquire data from or for emergency access to offsite monitoring equipment including."
Basis : As written, the criterion could be interpreted to mean that each operator should now acquire and maintain, at seme unspecified location offsite, an array of seismological instrumentation, radar for tornado vatches, etc.
Clearly, the objective should be to devise a scheme to obtain supplemental resources ss part of the emergency planning effort. There are many sources of geographical data, and radiological monitoring equipment can be obtained readily, should the need arise II.H.7 Delete.
Basis : As framed, this criterion is too broad to be useful and the more specific criterion of II.H.6 covers the same subject.
II.H.S Revise to read "Each operator shall provide meteorological instru-mentation and procedures necessary to develop estimates of projected doses in a timely manner, and provisions to obtain meteorological data from such other sources that may exist within the 10 mile Emergency Planning Zone."
1 Basis:
(1) There are a variety of techniques available that can be used to convert estimated releases to projected doses. The criterion should succinctly state the objective to be met rather than the specific procedure which is recommended by the NRC staff.
(2) A criterion should not make reference to some other document, particularly when the latter is still in a state of development; rather the objective should be clearly stated.
Paga 8 II.H.9 Revice to Read "Each operator shall provide for an onsite Operations Support Center from which e=ergency monitoring, repair and recovery tea =s would be dispatched. An alternate staging area shall be identified."
Basis: For some accident conditions, particularly, those in the General Emergency Condition it vould be preferable if emergency teams reported to a staging area away from a radioactive plume, highly conta=inated surfaces, or direct radiation. Shielding and ventilation in a room close to the reactor (even if such a room met NRC's habitability requirements for a control room) vill not remove the hazard associated with entrance and egress from the room and may result overall, in inereased personnel exposures.
II.I.1 Delete the ending phrase of the first sentence, "and shall..."
Basis :
(1) As noted on page 5 of NUREG 065h, "No single specific accident sequence should be isolated as the one for which to plan because each accident could have different consequences, both in nature and degree." This logic suggests that the exam les of NUREG 0610 remain just that. Reference to specific initiating conditions should be deleted.
II.I.5 Delete.
Basis: (1) This is redundant to II.H.8, and since II.I.5 refers to facility requirements any reference to such should be in Section II.H.
(2) Since II.H.12 calls for a central point for anlaysis of all field monitoring data, it is better to have the meteorological data at that location. There is no obvious reason why the TSC should
Paga 9 require a separate readout capability given the communications network required by NUREG 065h.
II.I.7 Revise to read: "Each organization... as lov as 10-6u c/c'c. "
Basis:
(1) The stated detection limit corresponds, roughly, to an exposure of 0.1 rem for a period of one hour; a value vell below PAG levels. Given the requirements for in-plant monitoring and diagnosis capabilities and the NUREG 0610 philosphy of precautionary protective measures there is no benefit from the II.I.7 detection limit (which baC 9 ally ignores other diagnostic capabilities).
(2)
The phrase "under field conditions in any kind of weather" is too general, and to the extent that it might include hurricanes, tornadoes or other severe weather conditions, it is unduly restrictive. (3) h last sentence is presumably an allusion to noble gas trapped on charcoal. Procedures exist to remove noble gas.
II.J h Delete the words "at or near this offsite location."
Basis: Generally, individuals should not be permitted to exit, the site if contaminated. Nonessential persons should not beccme con-taminated even for a General Emergency. However, if they should, there are many places where decontamination can be accomplished, either on-site or off-site as appropriate.
II.J.6 Replace the words " individuals" by " personnel essential to plant operation or the management of a site or general emergency."
Basis: Not all individuals on-site vill be in or make entries irto controlled areas or areas where hazardous levels of airborne activity exist.
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Paga 10 II.J.7 Delete.
Basis : It is clearly not the Operator's role to make recon:nendations on subjects outside his area of expertise and responsibility. The Operator, through the action of other criteria vill be providing prompt notification to responsible local and state agencies, and vill provide information about the status of the plant, releases and projected doses. The state plan can and should contain scenarios for i=plementing various types of protective actions based on infor-
=ation received from the operator -- including what courses of action to take when a general emergency is decleared and major releases are already occuring II.J.8 This criterion should be applicable to the state plan esd not the Operators plan.
Basis : Evacuation is an action to be decided by and implemented by state and local agencies (see second sentence, top of page h-2).
The estimates must be based on the techniques and methods of evacuation implemented by these egencies. The Operator cannot makr any meaningful estimates.
II.J.8 Delete second sentence.
Basfs: Appendix h should be offered ss for general guidance only.
Local jurisdications, the surrounding topography, and demographic setting can and should modify the arbitrary pie shape area called for in that Appendix.
II.J.10 Revise to read "(Table J-1 provides one possible way of clearly (a) identifying sectors. )."
Pag 2 11 0
Basis: The 22-1/2 sector is based on on-site reported vind direction. Actual trajectories vill not be linear and the specific areas that vill be protected should probably be based on local population distributions (e.g., housing developments, towns in the projected plune pathvay) and not on whether a town is in a given pie-shaped vedge. The alphanumeric 22-1/2 sector approach of Table 0
J-l introduces an unnecessary degree of co=plexity; whatever system that most confortably serves the needs of state and local officials should be acceptable.
I I.J.10 Delete.
(c)
Basis: This is properly within the scope of the state plan. It should be se.'.f-evident that several copies of the state plan vill be available at the reactor..
II.J.10 Revise to read, " Relocation centers in host areas."
(h)
Basis : This site relocation centers vill depend strongly on the specific site conditions. There is no good reason to abridge an orderly process of selecting relocation centers by setting priority on an arbitrary 15-20 mile distance.
II.N.1 Delete Note 3/.
Basis : No written information is provided to utilities of State and local governments as to how NRC response teams interface with State or utilities during an emergency. Information concerning the number of their personnel that may be involved, where they would expect to perform their functions, what their purpose would be, and what authority they would have are not known. Established emergency l
Paga 12 response plans vill be disrupted if HRC arrives and makes unexpected requests or demands on the State / local agencies / utility emergency organization. NRC interfacing with the State and local governmental agencies and the utility should be worked out ahead of time and be included in the Emergencies Plans.
II.3.2e (2) Delete.
Basis: This requirement would result in an unnecessary exposure to personnel (who may or may not be those called on in es emergency) and runs counter to Regulatory Guide 8.8.
The si=alated " drills",
together with the experience from day-to-day operations and training should provide effective, knowledgeable personnel, i
Co==ents on Aetendix 2 to NUREG 065h General The requirements set forth exceed that needed to adequately prepare for or restond to an e=ergency at a nuclear power plant. The extent of software in-strumentation and data acquisition required could introduce a level of comulexity that actually detracts from emergency assessment capabilities. This entire appendix and all references thereto should be deleted from this document. The troper vehicle for meteorological criteria should be a regulatory guide issued for com=ent and later implementation.
Selected Seecific Comments 1.
Under Pureose, the reference to routine releases is not appropriate for emergency planning and should be deleted.
2.
The acceptance criteria have little to do with actual emergency needs. The requirements should be coupled to and be of the same level of sophistication as the operator's techniques for converting plant effluent monitor readings to trojected dose (II.I.h on page h8), and should not call for information which is only periphically related to meteorological dispersion (the require-ment for dev point measurement is a notable example).
3.
Given the requirements for making dose projections when pla t equipment is inocerable or offscale (II.I.6 on page h8), and for access to another closeby source of meteorological data, a requirement for a redundant power to the meteorological system or redundant independent meteorological measurenent system is excessive and unnecessary and should be deleted.
h.
he requirement for a Class 3 real time model should be deleted. The additional insight gained from a Class 3 model is ove M elmed by the
Comments on Appendix 3 to MTREG 065h The requirement for notification of the public vithin 15 minutes after declaration of a general emergency has already been criticized. The event scenarios in the general emergency class, with few exceptions are slow to progress to core melting.
For example, the BWR sequences, on the average, would take roughly a day from the time that a general emergency would be declared per NUREG 0610 until core melting began and the " worst" sequence (not, per NUREG 0396, to be used as the planning bases) would not result in containment failure for more than three hours. In such circumstances, the 15 minute requirement has no foundation.
To then require a notification system which, as a designed objective, =ust be foolproof is too extensive. While the process of notification might begin immediately, its focus can and should be geared to the various protective action scenarios. Specifically, if the indicated action is a precautionary evacuation of people within 2 =iles downvind of the facility (as per NUREG 0610), then the notification need only be to those individuals. There is no circumstance where all individuals within 5 miles need to be notified within 15 minutes of the onset of a general emergency.
Page 2 uncertainties associated with meteorological variations distant from the site tarticularly with regar,d to a cround level release. The recuirements call for tailoring the " standard" dispersion estimators to account for local tenorgrachical features unfortunately, the accuracy af models to do so is ver/ toor.
5.
The remote interrogation capability requirement should be limited to the nearsite EOF.
6.
It is a constructive measure to attemet to standardize the software for meteorological data. However, it should be one which is already used at a majority of the reactor sites.
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