ML20030A235
| ML20030A235 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/02/1979 |
| From: | Dan Collins, Donaldson D, Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20030A234 | List: |
| References | |
| NUDOCS 8001140506 | |
| Download: ML20030A235 (63) | |
Text
.
UNITED STATES g.gg o
NUCLEAR REGULATORY COMMISSION f'I h c
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631 P ARK AVENUE e,
g KING OF PRUS$l A. PENNSYLVANIA 19406 a
s,, u.: y AUG 2 1979 MEMORANDUM FOR:
James M. Allan, Deputy Director, Region I FROM:
Radiological Investigation Team
SUBJECT:
RADIOLOGICAL INVESTIGATION TEAM RECOMMENDATIONS FOR FURTHER ACTION Enclosed are recomendations for further action th:' have resulted from evaluations made by the radiological investigation team.
These runmendations are either "long-tenn" TMI specific cr are for improvements applicable to all power reactor licensees. We request that you forward these to NRC management for evaluation and implementation.
V A. F. Gibson h? lbw D. M. Collins
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D. E. Donaldson T. H. Essigo mt &
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G. P. T0"na s
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- 0. C. SnacKieton f
g o o l I O 50G
18 aaaies-are-teseaHy-taken-at-an-area-indicating-the-highest radiatw '
leve If the plume is actually overhead, one would have no way df knowing that they re reading " shine".
N Consequently, if he'\\ere to take air sample using a /
selective medium end it indicated no detectable \\ activity,the surveyor ma/
y reach the conclusior that t.he plume contains no iodine, hen, in fact he did not even sample in the 31ume.
Recommendation:
Emergency environmental air sampling should make use f a dual media (i a parallel) sam ling technique.
A charcoal cartridge would e used as an ndicator o verify that the sample was, in fact, taken in the lume.
'he nele eive medium, silver zeolite, would be counted to determine iod concentratk r..
13.
Preblem:
Protective Action Guides and Protective Action Levels do not acequately consider potential radiological impacts.
Under existing guidance from the EPA and NRC, an actual release of radioactive materials must occur before the guidance is considered to be applicable.
Licensees calculate projected consequences based on actual source terms or field measurements then compare the results with adopted protective action guides, making apprcpriate recommendatiens to the state.
19 The TMI accident, however, indicates that the aforementioned philosophy may be sbort-sighted.
In comparing the projected doses calculated during the periods when uncontrolled releases were occurring, one finds that no protec-tive actions were warranted.
(While selective evacuation of children and pregnant woman was recommended by the Governor, it was intended to be conservative, but not necessary as a result of the comparison of projected doses with previously adopted action guides.) On the other br.ad, the volume of radioactivity in containment was of such a magnitude that had it been released, the action guides for evacuation may have been exceeded even before the state could have been notified.
Under such conditions, Protective Action Guides no longer represent an avoidable dose, but more correctly a dose commitment.
(With this perspective, it may have been more appropriate to institute protective actions around TMI that were more extensive than selective evacuation of children and pregnant woman.)
It would thus appear that, under certain conditions, it may be prudent to implement various of the range of protective actions, including evacuaticn, as a precautionary measure based on potential releases even though projected doses based on actual releases do not indicate that such actions would be appropriate.
Recommendation:
D The NRC, in coordination with the EPA Office of Radiation program, should formulate guidance for the implementation of protective actions in circum-
.,y.
,y.7,--
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!! MISSION BEFORE THE ATOiiiC SAFETY-AND LICENSING BOARD In the Matter of
)
1)
Docket No. 50-289 METROPOLITAii EDIS0N COMPANY, ET AL.
)
(Three itile Island, Unit 1)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO MOTION TO REO RECORD CONTAINED IN ECNP'S PROPOSED FINDINGS ON EMERGENCY in the above-captioned proceeding have been served on the August 25, 1981 following by deposit in the United States mail, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 25th da; of August,1981:
- Ivan W. Smith, Esq., Admi..istrative Ms. Marjorie M. Aamodt
^
R.D. #S Judge Atomic Safety & Licensing Board Panel Coatesville, PA 19320 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Thomas Gerusky Bureau of Radiation Protection Dr. Walter H. Jordan, Administrative Dept. of Environmental Resources P.O. Box 2063 Judge 881 W. Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 Mr. flarvin I. Lewis Dr. Linda W. Little, Administrative 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 Judge 5000 Hermitage Drive Raleigh, North Carolina 27612 Metropolitan Edison Company ATTN:
J.G. Herbein, Vice President George F. Trowbridge, Esq.
P.O. Box 542 Shaw, Pittman, Potts & Trowbridge Reading, Pennsylvania 19603 1800 M Street, N.W.
Washin9 ton, D.C.
20006 Ms. Jane Lee R.D. 3; Bo, 3521 Karin W. Carter, Esq.
Etters, Pennsylvania 17319 505 Executive House P. O. Box 2357 Walter W. Cohen, Consumer Advocate Harrisburg, Pennsylvania 17120 Department of Justice Strawberry Square, 14th Floor Honorable Mark Cohen Harrisburg, Pennsylvania 17127 512 D-3 Main Capital Building Harrisburg, Pennsylvania 17120 g
20 stances where the potential for exceeding action guides warrants the imple-mentation of the corresponding protective actions.
In addition, tne riin. snoulo provide guidance to licensees regarding the need to have provisions for assessing the potential consequences under such circumstances and the need to provide state and local officials with the results of such an assessment.
H ---Veblem.
At low wind ds (< 2 mph), frequent changes of wind direction can be experienced, resul, ting in an ill-defined or meandering effluent plume Consequently, radia en levels for any given area may tend to d rgo significant changes wit me, making the assessment of ra,dio ical impact N
/
a somewhat difficult task.
(TMl perienced this problem on numerous
>ccasions following the March 28 everit )
Recommendation:
/
\\,-
Licensees should be requ to install exposure rate moni ing devices
/
(which read dut in t control room) at the centerline of each f 16 sectors corresponding t the principal compass points.
These monitors shoul e
located a he site teundary (or at a greater distance if the maximum dose rate 's expected to ot ur beyond the site boundery).
The range of these 4
=st= eaesc m c.1-w m,e-sogstai..~.
s a y
o.
Thomas J. Germine Deputy Attorney General '
Division of Law - Room 316 1100 Raym6nd Boulevard Newark, New Jersey 07102 John Levin, Esq.
Allen R. Cari.er. Cliainen Pennsylvania Public Utilities Comm..
Joint Legislative Committee on Energy Box 3265 Post Office Box 142 Harrisburg, Pennsylvania 17120 Suite 513 Senate Gressette Building Jordan D. Cunningham, Esq.
Columbia, South Carolina 29202 Fox, Farr and Cunningham 2320 North 2nd Street Robert Q. Pollard Harrisburg, Pennsylvania 17110 609 Montpelier Street Baltimore, liaryland 21218 Louise Bradford 1011 Green Street Chaun 2y Kepford Harrisburg, Pennsylvania 17102 Juditi. H. Johnsrud Environmental Coalition on Nuclear Power 433 Orlando Avenue lis. Ellyn R. Weiss State College, Pennsylvania 16801 Harmon & Weiss 1725 I Street, N.W.
its. Frieda Berryhill, Chairman Suite 506 Coalition for Nuclear Power Plant Washington, D.C.
2000G Postponement 2610 Grendon Drive Mr. Steven C. Sholly Wilmington, Delaware 19808 Union of Concerned Scientists 1725 I Street, N.W.
Gail P. Bradford Suite 601 ANGRY Washington, D.C.
20006 245 W. Philadelphia St.
York, Pennsylvania 17401
- Atomic Safety and Licensing Appeal Board U.S. tiuclear Regulatory Commission g
Washington, D.C.
20555 ob (t M[
e
- Atomic Safety and Licensing Board Panel 1.ucinda Low Swartz U.S. Nuclear Regulatory Commission Counsel for NRC Staff Washington, D.C.
20555
- Secretary U.S. Nuclear Regulatory Commission ATTN: Chief, Docketing & Service Br.
Washington, D.C.
20555 William S. Jordan, III, Esq.
Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 e