ML20033D986
| ML20033D986 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/1989 |
| From: | Spessard R NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML20033D987 | List: |
| References | |
| NUDOCS 8905160031 | |
| Download: ML20033D986 (19) | |
Text
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t f(ptmalgIg UNITED STATES F
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NUCLEAR REGULATORY COMMISSION i
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WA$HINGToN D. C. 20666
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l MEMORANDUM FOR:
Edward L. Jordan, Chairman l
l Committee to Review Generic Requirements i
FROM:
R. Lee Spessard, Director Division of Operational Assessment Office for Analysis and Evaluation of Operational Data
SUBJECT:
DRAFT GENERIC LETTER REGARDING THE EMERGENCY RESPONSE DATA SYSTEM (ERDS)
It is requested that the Committee to Review Generic Requirements (CRGR) review the enclosed draft generic letter at its earliest convenience.
The enclosed draft generic letter provides information on the background,
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design, and NRC implementation policy for the ERDS system as well as requesting the voluntary participation of utilities in the ERDS implementation program.
This generic letter is addressed to all holders of operating licenses or construction permits and is sponsored by Gary G. Zech, Chief, Incident Response Branch.
The proposed generic letter and background information required by the CRGR Charter are enclosed, p R. g I
Lee Spessard, Director l
Division of Operational Assessment I
Office for Analysis and Evaluation of Operational Data l
l
Enclosures:
1.
ERDS Generic Letter 2.
CRGR tharter Item IV.B Contents of Packages Submitted to CRGR cc:
J. Thoma, NRR/DRP l
CONTACT:
John R. Jolicoeur, AE0D 49-24155 l
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UNITED $TATES n
NUCLEAR RECULATORY COMMISSION
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1 Generic Letter Addressees:
l The Commission is in the process of implementing an Emergency Response Data System (ERDS).
The ERDS will provide direct electronic transmission of a limited set of parameters from a licensee computer to the NRC during an i
emergency at a licensed nuclear power facility.
Implementation is proceeding on a voluntary basis and efforts are being taken to minimize the burden on the participating facilities.
We believe that the implementation of this system i
will be beneficial to both the NRC and licensees for the reasons explained l
below.
The Commission has defined the NRC's primary role in an emergency at a licensed nuclear facility as one of monitoring the licensee to assure that appropriate recommendations are made with respect to offsite protective actions.
Other aspects of our role include supporting the licensee with technical analysis and logistic support, supporting offsite authorities, including confirming the licensee's recommendations to offsite authorities, keeping other Federal agencies and entities informed of the status of the incident, and keeping the media informed of the NRC's knowledge of the status of the incident.
To fulfill the NRC's role, the NRC requires accurate, timely data on four l
i types of parameters:
(1) core and coolant system conditions must be known r
well enough to assess the extent or likelihood of core damage; (2) conditions l
inside the containment building must be known well enough to assess its status; (3) radioactivity release rates must be available promptly to assess i
the immediacy and degree of public danger by these pathways; and (4) the data l
from the plant's meteorological tower is necessary to provide insight into the potential distribution of a release.
Experience with the voice-only emergency communications link, currently utilized for data transmission, has demonstrated that excessive amounts of I
time are needed for the routine transmission of data and for verification or correction of data that appear questionable.
Error rates have been excessive and the frequency of updates has been unreliable.
The ERDS concept is a direct electronic transmission of selected parameters (Attachments 1 and 2) from existing facility electronic data systems which have been established by the licensees.
The ERDS would be for use only during emergencies at the facilities and would be activated by the licensees upon declaration of an ALERT or higher emergency classification to begin transmission to the NRC Operations Center.
The ERDS would be supplemented with voice transmission over the existing Emergency Notification System (ENS) of essential data not available on licensees' systems, rather than requiring modifications to existing systems.
The utility is expected to provide an output port on the appropriate data system and the necessary software to assemble the data to be transmitted.
No personnel action should be required for the acquisition or transmission of data after activation of the system.
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1 Accuracy and reliability are expected to be excellent because there are no human interfaces and many data syctems, such as the Safety Parameter Display System (SPDS), will incorporate automatic data validation. Timeliness should i
be excellent because the system would be immediately available and capable of i
rapid transmission with frequent updating.
Parametric coverage is expected to be excellent because the primary objective of the SPDS requirement is to provice the licensee with a tool for quickly assessing the overall status of the plant, i.e., the same need that the NRC faces.
Therefore, voice
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communications would be directed toward plant conditions and plant response rather than individual instrument readings.
Tests of the ERDS concept have been conducted with Duke Power Company (McGuire) and with Commonwealth Edison (LaSalle and Zion). These tests have demonstrated i
that there is great value in using electronic data transmission for obtaining a limited set of reliable, time tagged data.
The NRC response teams functioned more efficiently and their assessments were more timely.
Major improvements in the ability to focus on significant factors and to predict the course of events were noted.
The questions that were asked of the licensee were focused on the i
overall status and corrective actions being considered rather than simple data requests, thereby reducing the volume of voice communications.
k Actual work on the ERDS project began in 1985 with an initial feasibility survey conducted at approximately 80 percent of the licensed nuclear
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facilities in the United States.
An ERDS implementation contractor began work in January 1988.
The initial activities of the contractor have focused on an indepth review of the survey l
results, the production of final NRC hardware and sof tware designs and the procurement of the necessary hardware and software.
We are currently working i
with an initial set of utilities that have agreed to participate and we expect
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to establish initial plant connections in 1989. The lessons learned in implementation with this initial group will be fed back to the subsequent participants.
We hope to complete all plant connections by early 1992.
Attached is a list of frequently asked questions and our answers to assist you in a better understanding of the ERDS program.
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1 This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989.
The estimated average burden o
hours is 150 man-hours per licensee response, including assessment of the new recommendations, searching data sources, gathering and analyzing the data, and i
i preparing the required letters.
These estimated average burden hours pertain only to these identified response-related matters and do not include the time for actual implementation of the requested actions.
Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget, Room 3208, New Executive Office Duilding, Washirigton, D.C.
20503, and the U.S. Nuclear Regulatory Commission, Records and Reports Management Branch, Office of Administration an Resources Management, Washington, D.C.
20555.
3 We believe the benefits to the overall incident response capability are substantial and the costs to each utility are small. We would like to continue implementation on a voluntary basis.
The purpose of this generic letter is to solicit the participation of those utilities which have not yet volunteered in the EROS progrm>
Since we also plan to contact each utility individually, please provide an appropriate contact in your organization for followup discussion.
Should you have any questions, please feel free to call Gary Zech, Chief, Incident Response Branch at (301) 492 4193 or have your staff call John Jolicoeur, EROS Project Manager at (301) 492 4155.
Sincerely, James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Attachments:
1.
PWR Parameter List 2.
BWR Parameter List 3.
Questions and Answers List
ATTACHMENT 1
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1 PWR Parameter List i
3 i.I 1
Primary Coolant System Pressure
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l Temperatures Hot Leg Toeperatures Cold Leo
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Temperatures Core Ex t Thermocouples i
Subcooling Margin
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i Pressurizer Level i
RC$ Charging / Makeup Flow l
Reactor Vessel Level t
Reactor Coolant Flow (When Available) !
Reactor Power j
Secencarv Coolant System 1
i Steam Generator Levels t
Steam Generator Pressures Main Feoowater Flows i
Auxiliary / Emergency feedwater flows i
$4fety infection
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i High Pressure Safet'y Injection Flows i
LowPressureSafetyInjectionFlows j
Safety Injection Flows (Westinghouse) i terated Water Storage Tank Level Containment 3
Containment Pressure f
Containment Temperatures Hydrogen Concentration
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Containment Susp Levels Radiation Monitorino System Reactor Coolant Radioactivity i
Containment Radiation Level i
Concenser Air Removal Radiation Level Effluent Radiation Monitors Process Radiation Monitor Levels Meteorolooical Wind Speed Wind Ofrection Atmospheric Stability i
1 i
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ATTACHMENT ?
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ews earse.ter t4 s j
Primary Coolant System Reactor Pressure j
Reactor Vessel Level I
l Feoowater Flow Reactor Power l
I 1
Safety injection RCIC Flow l
HPCI/HPCS Flow l
Core Spray Flow j
LPCI Flow t
Consensate Storage Tank Level i
containment Drywell Pressure
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Drywell Temperatures Hydrogen ane Oxygen Concentration i
Drywell Sump Levels 4
i Suppression Pool Temperature Suppression Pool Level i
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i Rcdiation Monitorino System Reactor Coolant Radioactivity Level Primary Containment Radiation Level Condenser Off-Gas Radiation Level l
Effluent Radiation Monitor 4
Process Radiation Levels i
i Meteorological Wind Speed Wind Ofrection i
Atmospheric Stability
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ATTACHMENT 3 Detec 3/30/89 t
ERDS CUE $TIONS AND AN!WER$
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pill the implementation ef the ERDS affect the t:PC response role or the i
way that role is fulfilled?
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No.
The NRC response role was defined ano approved by the Comission and 4
would not change due to the ERDS.
Current response activities, including i
i discussions with the licensee, will be done more quickly and efficiently i
due to ERDS implementation but would not materially change.
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2.
What comunication protocol will be set up to accomplish the ERDS
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implementation?
A generic letter providing information about the ERDS and plans for its implementation will be promulgated to all licensees requesting their participation in the program.
i Cnce a utility has comitted to participate in the ERDS project, it I
will be contacted by telephone by the AEDD ERDS project manager and the {
NRC contractor to make arrangements for a site specific implea,entation schedule.
The t!PC will send a questionnaire to the licensee to obtain necessary l
preliminary information about the licensee's computer system and the ERDS I
For many licensees this questionnaire will also serve to parameters.
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confirm data obtained during the ERDS feasibility study conducted in 1987, Response to this questionnaire should be forwarded to the NRC and itt l
contractor.
Any questions or problems concerning the questionnaire should be referred to John R. Jolicoeur. AE00 ERDS Project Manager at (301) 492 4155 i
or Tony LaRosa. ERDS Project Manager. EI International at (208)
I 529-1000.
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After this information has been reviewed, we will proceed with the system inplementation process as described in the response to the following l
question.
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l 3.
How will the plant specific desion and imolementation aspects of ERDS be finalized with a facility?
Once a utility has comitted to participate in the ERDS project, an initial meeting will be held at the licensee's facilities with the NRC and our implementation contractor. The topics to be discussed include:
The data points available on the, licensee's computer to be i
transmitted that best satisfy the NRC parameter list.
The computer or computers that will be sending the cata stream and their operating characteristics.
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The data stream characteristics and communications method (ASCII, EBCDIC) to be used to transmit the data.
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Any hardware and software required for the ERDS implementation.
The
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plant specific implementation schedule based on plant capabilities.
l the need for hardware additions or modifications, and software i
development reouirements, i
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Subsequent ERDS development and initial testing will be done baseo on the agreed upon schedule, i
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What is the current program schedule?
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i-i Software is being developed by the NRC's contractor and should be completed by late sutrener 1989. The first utility on line to the NRC 1
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l Operations Center in Bethesda is scheduled for the fall of 1989 with subsequent connections scheduled over a 2 to 3 year period.
Will the implementation of the ERDS require significant equipment I
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modification or addition by licensees?
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i The only equipment requirements are for the hardware that is needed to I
provide the data stream from the current licensee equipment that processes t
t the requested data.
Should the computer system not be capable of producing i
the data stream for transmittal, then the ERDS will be implemented as site i
equipment modifications permit. Approximately 5 to 10 percent of the licensee's systems are running at close to 100 percent processing capacity!
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in the post trip or incident environment, and approximately 10 to l
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. 15 percent of the licensee systems are hardware limited (e.g. no available outputportforanERDSconnection).
The ERDS will follow, not drive, licensee equipment modifications. For those licensees where no new hardware is required, the costs per reactor unit are estimated in the range of $20K to $50K.
This estimate includes labor costs associated with software development, design change notice documentation, testing, and procedure development.
At the upper end of the cost spectrum, the survey revealed that two plant sites would require additional computer equipment to provide the necessary ERDS feed.
The hardware costs were estimated at $150K plus licensee staff time required to set up a custom system development effort with the appropriate contractor.
6.
Will the ERDS be considered safety orade or reovire redundant equipment?
No.
The ERDS feed will be as reliable as the current licensee equipment providing data to the licensee's own TSC and EOF.
The addition of new plant instrumentation or computer data points to provide ERDS data will not be required.
7 Will the current data list be expanded?
No.
The issue has been well studied since the Nuclear Data Link w originally proposed after TMI.
The development of the data list followed our detemination of our role in an emergency and provides the infonnation we need to perform that role.
Needed data not transmitted over ERDS will still be passed over the ENS.
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Must the ERDS be used to transmit drill data?
That is not a design requirement.
For those system configurations which only allow the transmission of real data, no modification will be expected.
However, if the licensee system is used for drills and can provide the transmission of the drill data, we would like to use the 1
capability for our drill participation.
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9.
Will the ERDS be an LCO or Tech Spec item?
4 No, i
10.
How soon does the NRC expect the system to be initiated after an Alert declaration?
The ERDS should be initiated when the licensee notifies the NRC of the declaration of an Alert or higher emergency classification.
- 11. Will the transmission of data point values for times prior to the time of the ERDS activation be required?
No.
Only the data values from the time of the transmission initiation will be required over the ERDS.
Information on initiating conditions and plant status will be provided over the verbal communication line as necessary.
Specifically, earlier parameter values will not be required.
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If a licensee system has the capability to transmit earlier data point values the NRC would like to utilize that feature but it clearly is not a design requirement.
12.
Dr.ce the ERDS is implemented. will continuous manning of the ENS (Red Phone) still be reouired?
Yes.
The ERDS will not eliminate the need for verbal transmits 1on of I
infomation such as licensee actions, reconsnended protective actions, and l
supplemental event specific data not provided by ERDS.
Emphasis will be given to producing no new impact on Control Room personnel due to the transmission of data over the ERDS.
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13.
Khat procedures and system controls will be recuired for the ERDS?
A procedure will be required for activation of the system during emergencies, probably an emergency plan implementing procedure, and for conducting system tests with the NRC., Any procedures or controls for i
system verification and validation or configuration control should be done i
in conformance with existing plant procedures as modified to require prompt notification of the NRC for any change which affects ERDS paremeters or the ERDS data stream.
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14 Will the ERDS data be provided to State authorities?
Although the !!RC is not soliciting or recomending State participation in the ERDS program, one provision of the systems cesign is user ports for States within the 10 mile plume exposure EPZ.
This provision was made to reduce the likelihood of different data being provided to the NRC and a State because of differing data sets where the State has decided to collect This provision is not expected to affect States that alreacy have a data.
data collection system.
If a State expresses a desire to participate in the ERDS program, the hRC will provide ERDS data to that State under a specific tiemorandum of Understanding.
The purpose of this Memorandum of Understanding would be to specify comunication protocols for clarifica-tion of ERDS data and data security requirements.
The NRC would provide those States with contractor developed software and make one output port available to the State from the NRC Operations Center.
The States would have to obtain compatible PC hardware and licensed software used in the ERDS system to receive the data.
This will ensure that all parties involved are using the same data base for their analysis.
Any request made by a State to set up the capability to receive the data will be discussed with the utility.
15.
Will the NRC reouire a periodic test of the ERDS, and if so how frequently?
The NRC does expect that periodic testing will be reovired to ensure system operability. Currently we expect that testing will be done quarterly.
Should system reliability pemit, the frequency of testing may
8-be reduced.
Testing of a State link portion of the system will be done with the NRC.
Therefore, no licensee participation will be required for this test,
- 16. Will participation in the ERDS program remain voluntary?
The NRC is reviewing the need for rulemaking to require the implementation of ERD 5 at all nuclear power plants in the event the voluntary program is not achievable.
It is anticipated that the provisions of a proposed rule would be the same as those of the voluntary implementation program currently in effect.
17,
)' hat will be the boundary of system maintenance responsibility?
The NRC will be responsible for maintenance of all parts of the ERDS l
system installed starting at the input port of the first ERDS-specific piece of hardware (e.g. modem for single feeder plants and multiplexer for multi-feeder plants).
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INCLOSURE 2 CRGR Item IV.B. Contents of Packages Submitted to CRGR i
Question:
l 1.
The proposed generic requirement or staff position as it is proposed to I
be sent out to licenees.
Response
The proposed position is set forth in the generic letter (Enclosure 1).
f Question:
i II.
Draft staff papers or other underlying staff documents supporting the f
requirements or staff positions.
Response
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1.
SECY-84-481, " UPGRADING THE NRC OPERATIONS CENTER'S EMERGENCY DATA ACQUISITION CAPABILITY", dated December 26, 1984.
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Question:
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t III.
Each proposed requirement or staff position shall contain the sponsoring
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office's position as to whether the proposal would increase staff requirements or staff positions, would implement existing staff requirements or positions, or would relax or reduce existing l
requirements or staff positions, j
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Response
The proposed generic letter requests a voluntary participation in the ERDS implementation process on the part of the licensees.
The ERDS
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system has been developed to fulfill the data collection needs of the i
NRC during an emer,:ecy at a licensed facility.
The authority to request this data w.iready contained in 10 CFR 50.72 and Appendix E of 10 CFR Part 50.
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Question:
i IV.
The proposed method of implementation along with the. concurrence (and any comments) of OGC on the method proposed.
Response
I The method of implementation will be the mailing of the generic letter.
OGC concurrence in this generic letter has been obtained.
h Question:
I V.
Regulatory analyses generally conforming to the directives and guidance
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of NUREG/BR-0058 and NUREG/CR-3568.
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Response
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The impact on most licensees should be minimal since they already have j
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computer systems that handle the data intended to be transmitted over t
EROS.
The licensees will have to provide hardware and software to assemble the data point values for transmittal to the NRC Operations l
l Center.
Our current estimates of licensee costs are $20K 50K for sof tware and 50-100K for hardware.
Note that at this point we are asking for
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voluntary participation on the part of the licensees.
l The current estimated cost of the ERDS system to the NRC is $2.6 million.
There is no estimated cost increase anticipated as a result of this generic letter.
Question:
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I VI.
Identification of the category of reactor plants to which the generic requirements or staff position is to apply.
Response
The proposed generic letter would apply to all holders of operating licenses or construction permits.
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l 1 l Question:
j VII.
For each such category of reactor plants, an evaluation which demonstrates how the action should be prioritized and scheduled in light of other ongoing regulatory activities.
The evaluation should document for consideration information available concerning any of the following factors as may be appropriate and any other information relevant and I
material to the proposed action:
1 (a) Statement of the specific objectives that the proposed action is designed to achieve; l
(b) General description of the activity that would be required by the
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licensee or applicant in order to complete the action; (c) Potential change in the risk to the public from the accidental offsite release of radioactive materiai; (d) Potential impact on iadiological exposure of facility employees and other onsite workers; (e) Installation and continuing costs associated with the action, including the cost of facility downtime or the cost of construction delays.
(f) The potential safety impact of changes in plant or operational complexity, including the relationship to proposed and existing regulatory requirements and staf f positions; (g) The estimated resource burden on the NRC associated with the proposed action and the availability of such resources; (h) The potential impact of differences in facility type, design or age on the relevancy and practicality of the proposed action; (i) Whether the proposed action is interim or final, and if interim, the justification for imposing the proposed action.
Response
The proposed generic letter is considered a Category 2 requirement.
The objectives of the proposed generic letter are to provide the addressees with the background information concerning the ERDS implemen-tation program and to solicit their voluntary participation in the program.
+4-l The other portions of this question are not applicable to this generic i
letter as it is not a requirement.
The nature of this action is to solicit voluntary participation in the ERDS project.
It therefore has no i
potential for impact on risk of radiological exposure, facility downtime, construction delays, etc.
l AEOD is proceeding with rulemaking, if necessary, to ensure 100 percent i
participation in the ERDS program.
AE00 considers the ERDS implementation i
to be of such high priority that we are proceeding with the voluntary l
implementation program in the interim, j
Question:
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VIII.
For each evaluation conducted pursuant to 10 CFR 50.109, the proposing office director's determination together with the rational for the i
determination based on the consideration of paragraphs (!) through (VII) l above that:
A.
there is a substantial increase in the overall protection of public 1
health and safety or the common defense and security to be derived from the proposal-j and i
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the direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection, i
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Response
t Although this program is voluntary, the Office Director concludes based i
on experience with the existing verbal only communication that implementation will result in a substantial increase in public health
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and safety by improvements in the NRC's ability to respond to a serious accident during the critical early hours and to provide better quality 6
of Headquarters support during an extended emergency.
The utility costs are relatively small in view of the benefits.
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Question:
l IX.
For each evaluation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office director's
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determination, together with the rationale for the determination, based on the considerations of paragraphs (I) through (VII) above, that:
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A.
the public health and safety and the common defense and security would be adequately protected if the proposed reduction in requirements or positions were implemented, and B.
the cost saving attributed to the action would be substantial enough to justify taking the action.
Response
This item is not applicable to the proposed generic letter because no relaxation or decrease in current requirements is being proposed, i
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