ML19345C798
| ML19345C798 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1980 |
| From: | Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Goller K NRC OFFICE OF STANDARDS DEVELOPMENT |
| References | |
| REF-SSINS-9300, RTR-REGGD-01.023, RTR-REGGD-1.023, TASK-OS, TASK-SS-926-4 NUDOCS 8012080380 | |
| Download: ML19345C798 (2) | |
Text
SS 9%-V pt$(.hu
~
000 Kit nunNR 0
3 ND RULE kf p'l %
.7 UNITED STATES
'd
$ YQ w d[k g
NUCLEAR REGULATORY COMMlESION i{&.%
WASHitJGTOfJ. D. C. 7en:
SSINS:
93p0 h
75 o
ra ROV 14 1990 N
h.b
- i n
Ed MEMORANDUM FOR:
K. R. Goller, Director, Division of Siting Health y
and Safeguards Standards, OSD 0
x FROM:
Leo B. Higginbotham, Chief, Radiological Safety Branch, IE
SUBJECT:
COMMENTS ON PROPOSED REVISION 1 TO REGULATORY GUIDE 1.23, METEOROLOGICAL PROGRAMS IN SUPPORT OF NUCLEAR POWER PLANTS After thinking a bit more about all the post-TMI safety upgrading actions required of licensees, we have given further consideration to the subject Regulatory Guide. Our opinion is that many of the positions are not justifiable, e.g., multiple meteorological towers, dual recording systems, redundant electrical supplies, mobile meteorological data collection system, incoming solar radiation instrumentation, and especially a 10 CFR 50, Appendix B Quality Assurance program.
These positions do not appear to be justifiable either for routine operations or accident conditions.
I For routine operations, the environmental radiation doses are maintained to such small, negligible levels (under Appendix I to 10 CFR 50 and 40 CFR 190) that attempting to " fine tune" to an extreme one parameter (meteorology) of a conservative dose calculational method is not consistent with the uncertainty inherent in the other variables.
For accident considerations, the guidance is greatly overdrawn for the level of sophistication needed for adequate and timely dose calculations.
In actuality, decisions on evacuation will be made on the potential for significant releases of radioactivity, with potential doses being based on de. fault meteorology, not real time meteorology. This type and level of back-up to be established for meteorological equipment is not even required for the in-plant effluent monitoring equipment, which is of more importance for the actual dose calculational process.
Overall, the tone of the proposed revision strikes us as being similar to that of a research project.
Indeed, this level of sophistication would seem to rival much of the research effort that has been expended in the development and confirmation of meteorol.ogical models.
Before the NRC implements a program of such a scope, we suggest (1) the costs and benefits should be more carefully examined, and (2) the overall contribu-tion to the public nealth r.nd safety should be looked at and balanced wi
/ %Ir
/p Nh. hQ
_ n.....g 7. 4,.......
- e gy a
o i #h$ss
/p/
.g 3@G N 8019080 nao rr-0
~
o K. R. Goller '
all the other requirements currently being imposed on nuclear power plant licensees at this time. The estimated cost to the industry of $10,000 to
.$20,000 per site seems a gross underestimation; the program appearing to us as one which might easily require a continuing effort for several man years per year.
This manpower effort alone would exceed the estimated $20,000.
A basic meteorological program is needed at each nuclear power plant site.
But, the details proposed in the revision to Regulatory Guide 1.23 appear to be an "over-kill" in one area without considering the overall scope and depth of meteorological data, dose assessment, and emergency planning. 'There is a need for a back-up meteorological program for evaluating incidents; however, this back-up program should be established on a national level (e.g., ARAC),
not on an individual plant level. We are not convinced that its justifable to require each facility to establish an elaborate meteorological program with back-up capability as outlined in the proposed revision. We suggest that the proposed revision be re-thought, with due consideration given to the other requirements being imposed to increase safety.
hv Leo B. Higgi(MEnam Chief, Radiological Safety Branch Division of Safeguards and Radiological Safety Inspection, IE cc:
H. D. Thornburg B. Grimes W. Kreger CONTACT: Stew Bland Jim Wigginton (28188)
I
- -, -