ML19340A957
| ML19340A957 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, Zion  |
| Issue date: | 03/31/1977 |
| From: | Goller K Office of Nuclear Reactor Regulation |
| To: | Brian Lee COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8009100832 | |
| Download: ML19340A957 (5) | |
Text
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!,iA 3 1 1977 DISTRIBUTION:
Docket DEisenhut NRC PDR TAbernathy' L. PDR JBuchanan ORB #1Rdg.
ACRS (16)
Docket 'los.:
50-10, 502237, 50-24?, 50-254 VStello 50-265, 50-295 and 50-304 KGoller TCarter Attorney, 02LD OI&E (3)
D. Davis Comonwealth Edison Company ASch*:encer 7
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ATTN:
Mr. Byron Lee, Vice President G.Zech P. O. Box 767 DSilver Chicago, Illinois 60670 P0'Connor
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j SSheppard
Dear Mr. Lee:
RDiggs BGrimes The results of recent inspection activities by representatives of the NRC Office of Inspection and Enforcement Region III, have indicated to us a need to revise certain implementing procedures of your generic Comonwealth Edison Generating Stations Emergency Plan (GSEP) which is intended to apply to all of your operating nuclear power stations.
These inspection activities included the review of the imple enting f
procedures of GSEP and discussions with the Environmental Director at you Zion Station.
The eniilosure to this letter describes the areas in which we believe i-the implementing procedures should be revised to confonn to the federal guidance cited.
We therefore request that you review the implementing procedures of GSEP in ligSt of the enclosure, develop appropriate revisions and submit a revised set of GSEP implementing procedures for our review within sixty days of receipt of this letter.
Your submittal should e
include a proposed schedule for implementing these revised procedures i
on each of your operating nuclear power facilities.
i Sincerely,
/ w//c,
Kar'l D. Goller, Assistent Director for Operating Reactors Division of Operating Reactors
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Enclosure:
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e; Discussion of GSEP Implementing'
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Comonwealth Edison Company
- cc: Robert J. Yollen, Esquire 109 North Dearborn Street Chicago, Illinois 60602 Dr. Cecil Lue-Hing Director of Research & Development Metropolitan Sanitary District' of Greater Chicago i
100 East Erie Street l
Chicago, Illinois 60611 Waukegan Public Library 128 North County Street Waukegan, Illinois 60085 Mr. John W. Rowe l
Isham, Lincoln & Beale Counselors at Law l
One First National Plaza, 42nd Floor Chicago, Illinois 60603 i
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~l DISCUSSION OF GSEP IMPLEMENTING PROCEDURES (COMMp %'EALTH EDISON GENERATING STATIONS _- EMERGENCY PLAN)
The Commonwealth Edison Generating Stations Emergency Plan (GSEP) was transmitted to NRC with a letter dated February 18, 1975, and was accepted by NRC as meeting the requirements of 10 CFR Part 50 Appendix E by letter, Ziemann to Abel dated May 23, 1975.
GSEP includes in Table 4.2-1 Guidelines for Categorization of Radiological i
Incidents for an Alert Stage and an Emergency Stage, Offsite, respectively of 0.5 Re= and 5 Rem Whole Body dose and 1.5_ Rem and 15 Rem Thyroid dose.
i These values were deemed acceptable although they are somewhat lower than f
I' the Protective Action Guidelines (PAGs) published by the U.S. Environmental l
Protection Agency in January 1975 in the " Emergency Response Protective f-PAGs are Action Guides-Airborne Releases from Fixed Nuclear Facilities."
The document states, " Projected I
defined.in terms of ranges or projected dose.
l dose is the dose that would be received by individuals in the population I
if no protective action were taken."
group from the contaminating event further states, "The greater sensitivity of children and The document fetuses indicates that these initial groups will in most circumstances dictate the decision on when protective action is initiated."
In a 1.
discussien with the Com=onwealth Edison Environmental Director by NRC 1&E representatives during recent inspections visits, the Environmental k
Director indicated that a recommendation would not be made during an b
emergency for selective evacuation. The guidance referenced above if there are identifiable concentrations of chilt.ren or reconmends that, women of childbearing age in the vicinity, these should be given special
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. consideration in the implementation of protective actions.
Further discussion of implementing procedures with the I&E inspectors indicated that the procedure for ihitial notification to offsite state and local authorities, who have responsibility and authority for imple-menting evacuation, includes the marshalling of Commonwealth personnel to make of fsite surveys and dose projections on the basis of the surveys.
j The total time between the accident and notification to offsite authori-ties may then be as long as three hours.
Although this procedure may be reasonable for' accidents of lesser potential consequences it is our judgment such a delay would be unnecessarily excessive for an event involving that I'
The need for prompt assessment and notification is substantial core damage.
e=phasized in the USAEC (NRC) Standard Review Plan Section 13.3-Emergency l
Planning Acceptance Criteria which specifies " Completion of initial accident i
assessment measures, including dose projection and notification to offsite j.
I' authorities within fif teen minutes...." Further guidance is in Regulatory i'
- i Guide 1.101, Section 4.15, " Action-levels for severe short-term situations
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requiring rapid implementation of protective actions should be defined in terms of readily available information such as readings of effluent j
1 monitors or other onsite monitor indications.
leplementation of protective
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actions may also bc based on confirnatory measurements taken in the field to the extent it can be shown that field measurements can be taken and v.;
evaluated rapidly enough to permit adequate time for the protective actions to be accomplished."
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-3 The i=ple=enting procedures for GSEP should be reviewed and evaluated for confor=ance to the recocsendations noted above.
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