ML20039H033

Responds to FOIA Request for SECY-81-188 Re Emergency Preparedness.Forwards Document & Sj Chilk 810422 Memo to Wj Dircks

ML20039H033
Person / Time
Issue date:	12/01/1981
From:	Felton J NRC OFFICE OF ADMINISTRATION (ADM)
To:	Elliott C THOMAS & HAIR
References
FOIA-81-419 NUDOCS 8201190448
Download: ML20039H033 (1)

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s UNITED STATES j

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i h)h Charles W. Elliott, Esquire

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Thomas and Hair 123 North Fifth Street - Suite 101 IN RESPONSE REFER j

Allentown, PA 18102 TO F01A-81-419

Dear Mr. Elliott:

This is in reply to your letter dated October 13, 1981, in which you requested, pursuant to the Freedom of Information Act, a copy of SECY-81-188 concerning Emergency Preparedness.

In response to your request, a copy of SECY-81-188 is enclosed. Also enclosed is a copy of a related document identified as a memorandum dated April 22, 1981, To: W. J. Dircks, From: S. J. Chilk,

Subject:

SECY-81-188 - Emergency Preparedness.

Since J

M. Felton, Director ivision of Rules and Records Office of Administration

Enclosures:

As stated I

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8201190448 811201 PDR FOIA ELLIOTT81-419 PDR

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'1 March 20,1981 1-SECY-81-188

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POLICY ISSUE (Notation Vote)

For:

The Comissioners From:

William J. Dircks Executive Director for Operations

Subject:

EMERGENCY PREPAREDNESS

Background:

NUREG-0694, "TMI-Related Requirements for New Operating Licenses," stated that prior to fuel loading it was necessary to comply with the then effective Appendix E to 10 CFR Part 50, " Emergency Plans for Production and Utilization Facilities," Regulatory Guide 1.101, "Emer-gency Planning for Nuclear Power Plants," and for offsite plans to meet the essential elements of NUREG-75/111 or have a favorable finding from FEMA. The submission and evaluation of emergency plans against the standards of NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," was required prior to the issuance of a full power license.

Copies of the appropriate pages from NUREG-0694 are attached as back-ground information in Enclosure 1.

When NUREG-0737, " Clarification of TMI Action Plan Requirements," was being written, the timing for evaluation of offsite plans as set forth in NUREG-0654 was inadvertently changed to include those licensees requesting permiss, ion to conduct only fuel loading or low power testing. These changes appeared as entries on page 2-11 of a table to NUREG-0737 (Enclosure 2) i as background information.

1 Discussion:

10 CFR 5 50.47 became effective on November 3, 1980, and required compliance with emergency planning and preparedness standards prior to the issuance of operating licenses, including those authorizing fuel loading and low power testing.

5 50.47(c) nevertheless provides a flexible approach foi assessing the necessary CONTACT:

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.t The Commissioners degree of compliance, with the result that licensees requesting low power testing and fuel loading operating licenses can receive such licenses without having to meet every individual factor set forth in 1 50.47, at least at that level of operation, provided that FEMA's findings support that approach.

As discussed with the Comission prior to the issuance of NUREG-0694, it is unnecessary to require extensive offsite emergency cap-i ability at nuclear power plants where the licensee is performing either initial fuel loading or operating

'l initially at low power levels because of the low potential for significant offsite releases.

In a parallel manner, 10 CFR R 50.57(c), governing adjudicatory hearings for the issuance of operating licenses, is specifically framed in terms of requiring Board findings only on those matters significant for the activity to be authorized. Thus, 5 50.57(c) pro-vides a basis for making a distinction between the Licensing Board findings necessary for issuance of full power operating licenses and those necessary for issuance of operating licenses authorizing low power testing or fuel loading.

A literal interpretation of the table in NUREG-0737 (Enclosure 2) could lead to a conclusion that the Commission intended to disregard the flexible, case-by-case approach expressly provided for in il 50.47(c) and 50.57(c), and to require that licensees comply with every f acet of emergency planning contained in 5 50.47 as prerequisite to the issuance of every operating license,

,even those where the activity sought to be authorized is fuel loading or low power testing.

The staff did not intend, nor does it believe that the Commission intended, to interpret the table appearing in NUREG-0737 with respect to the effectiveness of 10 CFR 5 50.47 so literally as to eliminate the flexibility provided by 10 CFR ll 50.47(c) and 50.57(c).

Consequently, the staff proposes that the Comission approve the suggested changes to the table in NUREG-0737 (Enclosure

2) to clarify the differences between the emergency planning requirements contained in 10 CFR S 50.47 that must be met prior to full power authorizations versus those prerequisite for operating license authorizations only for fuel loading or low power testing.

1 1

The Comissioners Enclosure 2 contains page 2-11 as it appears in NUREG-0737 marked with the staff's recomended conforming changes. is the same page retyped as it would be issued.

The staff believes it is important to issue this change promptly to serve as the basis for consideration of low power applications now in the hearing process.

Recomendation:

That the Comission approve the changes to page 2-11 of NUREG-0737 as provided in Enclosure 3.

( Mg William J. Dircks Executive Director for Operations l

Enclosures:

1.

NUREG-0694 Pages-Background j

Information 2.

NUREG-0737 Marked Page 2-11 3.

NUREG-0737 Final Page 2-11

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Commissioners' coments should be provided direcity to the Office of the Secretary by c.o.b. Monday, April 6, 1981.

Commission Staff Office comments, if any, should be submitted to the Comissioners NLT March 30, 1981, with an information copy to the Office of the Secretary.

If the paper.

is of such a nature ~ that it requires additional time for analytical review and coment t the Comissioners and the Secretariat should be apprised of when coments may be expected.

DISTRIBUTION Comissioners l

Commission Staff Offices l

Exec Dir for Operations ACRS ASLBP Secretariat

NUREG-0694 II.K.3 FINAL RECOMMENDATIONS OF B&O TASK FORCE

• C.3.9"*

For Westinghouse-designed reactors, modify the pressure integral derivative controller, if installed on the PORV, to elimi ate spurious n

openings of the PORV.

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C.3.10 For Westinghouse-designed reactors, if the anticipatory reactor trip upon turbine trip is to be modified to be bypassed at power levels less than 50 percent, rather than below 10 percent as in current designs, demonstrate that the probability of a small-break LOCA resulting from a stuck-open PORV is not significantly changed by this modification.

C.3.11 Demonstrate that the PORV installed in the plant has a failure rate equivalent to or less than the valves for which there is an operating history.

C.3.12 For Westinghouse-designed reactors, confirm that there is an anti-cipatory reactor trip on turbine trip.

These requirements shall be met before fuel loading.

III.A.1.1 UPGRADE EMERGENCY PREPAREDNESS Comply with Appendix E, " Emergency Facilities," to 10 CFR Part 50, Regulatory Guide 1.101, " Emergency Planning for Nuclear Power Plants," and for the offsite plans, meet essential elements of NUREG-75/111 (Ref. 28) or have a favorable finding from FEMA.

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'The B&O recommendations were not specifically delineated as to fuel-loading or full power requirements prior to the review of Sequoyah, North Anna 2, and Salem 2.

The NRR staff is presently confirming compliance with these four items for these plants.

• • Table C.3 of the Action Plan lists the requirements derived from final recommendations of the B&O Task Force.

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NUREG-0E4 Enclosure i This requirement shall be met before fuel loading.

III.A.1.2 UPGRADE EMERGENCY SUPPORT FACILITIES Establish an interim onsite technical support center separate from, but close to, the control room for engineering and management support of reactor opera-tions during an accident.

The center shall be large enough for the necessary utility personnel and five NRC personnel, have direct display or callup of plant parameters, and dedicated communications with the control room, the emercancy operations center, and the NRC.

Provide a description of the permanent technical support center.

Establish an onsite operational support center, separate from but with communica-tions to the control room for use by opc ations support personnel during an accident.

Designate a near-site emergency operations facility with communications with the plant to provide evaluation of radiation releases and coordination of all L

.onsite.and offsite activities during an accident.

These requirements shall be met before fuel loading.

See NUREG-0578, Sections 2.2.2.b, 2.2.2.c (Ref. 4), and letters of September 27 (Ref. 23) and November 9, 1979 (Ref. 24) and April 25, 1980 (Ref. a).

i III.D.3.3 INPLANT RADIATION MONITORING Provide the equipment, training and procedures necessary to accurately determine the presence of airborne radiciodine in areas within the plant where plant t

personnel may be present during an accident.

This requirement shall be met before fuel loading.

See NUREG-0578, 1

l Section 2.1.8c (Ref. 4), and letters of September 27 (Ref. 23) and November 9, j

1979 (Ref. 24).

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C.2.16 For B&W-designed reactors, evaluate ?.he effect of reactor coolant pump damage and leakage following a small-break LOCA concurrent with a loss of offsite power that results in the loss of seal cooling.

See letter of August 21, 1979 (Ref. 30).

These requirements shall be met before issuance of a full power license.

II.K.3 FINAL RECOMMENDATIONS OF B&O TASK FORCE C.3.3*

Assure that any failure of a PCRV or safety valve to close will be reported to the NRC promptly.

All challenges to the PORVs or safety valves should be documented in the annual report.

This requirement shall be met before issuance of a full power license.

III.A.l.1 UPGRADE EMERGENCY PREPAREDNESS Provide an emergency response plan in substantial compliance with NUREG-0554,

" Criteria for Preparation and Evaluation of Radiologt' cal Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (which may be modified as a result of public comments solicited in early 1980) except that only a description of and completion schedule for the means for providing prompt notification to the population (App. 3), the staffing for emergencies

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in addition to that already required (Table B.1), and an upgraded meteorolog 4al program (App. 2) need be provided (Ref. 10).

NRCwillgivesubstantialweight[

findings on offsite plans in judging the adequacy against NUREG-0654.

Perform an emergency response exercise to test the integrated capability and a major portion of the basic el'ments existing within emergency preparedness plans and organizations.

This requirement shall be met before issuance of a full power license.

^ Table C.3 of the Action Plan lists all of the recommendations of the B&O Task Force.

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P ENCLOSURE 2 (CONTINUED)

Clarift-Implemen-Plant Require-Clarlff-Tech cation Shortened tation Applica-ments cation Spec.

Item Title Description Schedule bility Issued issued Req.

Remarks Encl. 3 No II.K.3 Final recommendations, c.

New analyses In accordance All B&O task force with review (continued) schedule

31. Plant-specific analysis 1/1/83a All Enc 1. 3 No Encl. 3 As

44. Evaluate transients 1/1/81A BWR with single failure required

45. Manual depressurization 1/1/81A BWR Encl. 3 No

46. Michelson concerns fuel load BWR Encl. 3 No Ill.A.1.1 Emergency Short-term improvements

1. _-! ': d W

.84 W ee-JEAAEfM)63* No

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""" 0 -0W preparedness, (9

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short ters (W"

l Ill.A.1.2 Upgrade emergency

1. Establish TSC, OSC, TBD All 9/27/79 11/9/19 No support facilities EOF (interin basis)

2. Design TBD TBD 180 TBD TBD TBD TBD TBD TBD

-)TBD

3. Modifications u

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.Ner-pu-8/19/80 NUREG-III.A.2 Emergency

1. Upgrade emerger.cy plans

-Fue n uad preparedness to App E, 10 CFR 50 E.M.

%e 0654 Jhr-f#"

2. Meteorological data d

All 6/26/80 NUREG-0654 111.D.1.1 Primary coolant Measure leak rates &

Full power All 9/27/79 11/9/19 Yes outside estabilsh program to Encl. 3 containment keep leakage ALARA III.D.3.3 Inplant In radiation

1. Provide means to Fuel load All 9/27/79 11/9/79 Yes monitoring determine presence Encl. 3 of radiolodine

2. Modifications to 1/1/81 or All 9/27/19 11/9/79 Yes accurately measure prior to radiolodine licensing Enc 1. 3 I

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111.D.3.4 Control-room

1. Identify and evaluate Full power All 6/26/80 Encl. 3 No habitability potential hazards

2. Schedule for Full power All 6/26/80 Encl. 3 No rn ; -

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modifications

3. Modifications Full power All 6/26/80 Encl. 3 Yes

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CC Four months before operating, license is issued or 4 months before date indicated.-

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Requirement formally issued by this letter.

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ENCLOSURE 2 (EONTINUED)

Clarlft-Implemen-Plant Require-Clartft-Tech cation Shortened tation Applica-ments cation Spec.

Item Title Description Schedule bility Issued Issued Req.

Remarks II.K.3 Final Recomiendations, c.

New analyses In accordance All Encl. 3 No BLO task force with review (Continued) schedule

31. Plant-specific analysis 1/1/83a All Encl. 3 No

44. Evaluate transients 1/1/Ola BWR Encl. 3 As with single failure required

45. Manual depressurization 1/1/Ula DWt Encl. 3 No

46. Michelson concerns fuel load BWR Encl. 3 No III.A.I.!

Energency iho.-t-term fmprovements Conglete No preparedness, short term lit.A.I.2 Upgrade emergency

1. Establish TSC, OSC.

IBD All 9/27/79 11/9/19 No support facilities EOF (interim basis)

2. Design TBD TBD IBD TBD TBD y

3. Modifications IBD TBD TBD TBD TBD l

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Ill.A.2 Emergency

1. Upgrade emergency plans full power All 8/19/80 NUREG-Yes preparedness to App E, 10 CfR 50 0654

2. Heteorological data full power All 6/26/80 NUREG-Yes 0654 Ill D.l.1 Primary coolant Heasure leak rates &

Full power All 9/27/19 11/9/19 Yes outside establish program to Encl. 3 containment keep leakage ALARA III.D.3.3 Inplant 12 radiation

1. Provide rieans to fuel load All 9/27/79 11/9/19 Yes monitoring determine presence Encl. 3 of radiolodine

2. Hadifications to 1/1/81 or All 9/27/19 11/9/79 Tes accurately measure prior to radiolodine licensing Encl. 3

!!I.D.3.4 Control-room

1. Identify and evaluate Full power All 6/26/80 Encl. 3 No 5 $*

habitability potential hazard, o g;

2. Schedule for Full power All 6/26/80 Encl. 3 No m a modifications C C

3. Modifications full power All 6/26/80 Encl. 3 Yes 2C AJ l

W AFour maths before operating Ilcense is issued or 4 months before date indicated.

• Requirement fornally issued by this letter.

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IN RESPONSE REFER TO S81-188

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'e UNITED STATES l 'y.,,,. 7 [,j NUCLEAR REGULATORY COMMISSION

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WASHINGTON D.C. 20555

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% ' b' ko April 22, 1981 OFFICE OF THE SECRETARY MEMORANDUM FOR:

William J.

Dircks, Executive Director for Operations FROM:

Samuel J. Chilk, Secreta ' ' b

SUBJECT:

SECY-81-188 - EMERGENCY P REP ifEDNESS V

This is to advise you that the Commission (with all Commissioners approving) has approved the changes to page 2-11 of NUREG-0737 as provided in Enclosure 3 of the subject paper.

The Office of Inspection and Enforcement was informed of this action by telephone on April 22; 1981.

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Chairman Hendrie d

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Commissioner Gilinsky T

Commissioner Bradford Q-ghg Q}

Commissioner Ahearne

,y Commission Staff Offices Director, Inspection and Enforcement t

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CONTACT:

E.

W. McGregor (SECY) i 41410 Y

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