ML20040C511
| ML20040C511 | |
| Person / Time | |
|---|---|
| Issue date: | 01/11/1982 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20040C507 | List: |
| References | |
| NUDOCS 8201280023 | |
| Download: ML20040C511 (14) | |
Text
0 08C0 UfjlTED STATES
,fg NUCLEAR REGULATORY COMMISSION E
WASHINGTON, D. C. 20555 3 i; ul
\\'*v /
JAN 111932 i
MEMORANDUM FOR: Victor Stello, Jr., Deputy Executive Director Regional Operations and Generic Requirements FROM:
Richard C. DeYoung, Director Office of Inspection and Enforcement SUEJECT:
EVALUATION OF CRGR PROPOSED REQUIREMENTS ON EMERGENCY RESPONSE FACILITIES As indicated in my memorandum of January 5,1982, the Division of Emergency Preparedness has prepared a detailed evaluation of the relationship of the proposed requirements formulated by the CRGR staff to existing regulations and guidance.
Comparisons for the various proposed requirements in your December 29, 1981 memorandum are given in the enclosures. We will not comment further" on the SPDS and control room review sections as NRR has the lead responsibil'ity on SPDS design and its relation to control room reviews.
O Richard C. De oung, irector Office of In/pectio and Enforcement
Enclosures:
As stated cc w/ enclosures:
H. Denton R. Minogue 1
1 8201280023 820112 PDR REVGP NRCCRGR PDR
DEP GEfiERAL C0!!?!Ef1TS ON CRGR PROPOSED RE0VIREftENTS 1.
There appears to be some confusion in the requirements between emergency operating procedures and emergency implementing ' rocedures.
p 2.
There.is no recommended minimum staffing level or augmentation schedule for licensee emergency personnel.
3.
The use of the undefined term "uninterruptable" for communications and data flow can be interpreted as requiring 100% availability for emergency response facilities.
4.
The omission of any radiological habitability guidance for the TSC would make that facility useless under many conditions of a Site Area Emergency or General Emergency Class.
5.
The omission of the Commission's requirements for location and habitability of the EOF will put the Commission in the position of changing their own require-ments when most licensees have already started building facilities to meet their requirements.
6.
The implication that the data set for the various Emergency Response Facilities should be different and that only those in a limited set in the E0F are needed for the NDL iA Jn opposition to the recommendations of the Safety Data Inte-gration GroupTg (RC which was was responsible for this development.
Limiting access to information is inadvisable.
7.
The use of radiation protection levels in 10 CFR 20 are too restrictive-and not possible under emergency conditions at a nuclear power plant.
s a
O l
e 4
e
C0'1MENTS ON INTRODUCTORY MATERIALS FOR CRGR PROPOSED REOUIREtiENTS Page 1 - Statement is made at end of first paragraph that "significant progress has been made in this area".
The implication is that all of the progress is in the offsite area, especially after reading the first sentence of the second paragraph.
CRGR should recognize that both onsite and offsite plans had to be implemented 04/01/81 and that the " slower" progress refers to emergency response facilities, not necessarily emergency plans.
Page 3 - Under the section on "Use of Existing Documentation", there is a strong statenent that "under no circumstances" should the items in the documents be misconstrued as requirements.
The CRGR should recognize that some items in the docunents are either incorporated -into, or are referenced in, the Regulations.
For example, the 16 Standards codified in 10 CFR 50.47(b) are identical to the " Planning Standards" found in Section A-P of Part II of NUREG-0654, and the EPZ concept, codified in 10 CFR 50.33(g), is discussed in NUREG-0396; also Regulatory Guide 1.101, Revision 2, endorses NUREG-0654 The following references should be added:
NUREG-0396 NUREG-0818 Regulatory Guide 1.101, Revision 2 Page 4 -
Item 3; In some cases, the proposed TSC and EOF structures are not independent of one another.
Emeroency Response Facilities (no page number)
Reference 10 CFR 50.54(g) is incorrect, it should be 10 CFR 50.54(a).
Reference to 10 CFR.50.47(b) should be rnore specifically referenced as 10CFR50.47(b)(8).
Neither 10 CFR 50.54(g) nor 10 CFR 50.54(q) refer to requirements for prompt communications, or for adequate methods and equipnent for assessing and monitorng potential offsite consequences.
The prompt communications requirement is found in 10 CFR 50.47(b)(6) and the methods and equipment requirement is found in 10 CFR 50.47(b)(9).
The Appendix E reference for emergency response facilities should be more specifically referenced as Appendix E, Part E.
Page 4 - Are the letters which are referenced in the same category as the regulations which are referenced ? e.g., are the letters
" Actual Regulatory Reouirements"?
Technical Support Center (no page number)
Under " Recommended Requirements", Item 1 appears to be contrary to the statement on Page 2 which says that " flexibility is.nandatory".
2-C0ftMENTS ON INTRODUCTORY MATERIALS FOR CRGR PROPOSED REQUIREMENTS Reaulatory Guides 1.97 and 1.23 (no page number)
Pegarding Item 2, actions to be taken prior to issuance of Reg. Guide 1.23 a)
Reg. Guide 1.23 statements will assure consistency with NUREG-0696 criteria
[
b)
No backup system is necessary to perform probabilistic risk assessment or any other statistical evaluation c)
Consistency will be assured 0
1 9
I O
e
+ g 9
0
e COMPARIS0N OF NUREG CRITERIA AND CRGR PROPOSED REQUIREMENTS STAFFING PRESENT CRITERIA DOCUMENTATION CRGR REOUIREMENT CHANGED 1.
EP Implementing Proce-10 CFR 50 App. E Pevise E0Ps to make them Yes (1) dures' required 180 days symptom oriented and con-hefore issuance of OL sistent with SPDS, etc.
2.
Staffing shall include NUREG-0696 No specific requirements No sufficient technical, other than " pre-designated engineering, and senior designated licensee personnel" officials to provide needed support 3.
A senior designated NUREG-0696 A predesignated senior No licensee official shall shall be in charge coordinate activities in TSC & another such official in E0.F (1) CRGR is apparently confusing E0Ps with emergency implementing) procedures.
CRGR should refer to NUREG-0799 and NUREG-0737, not 10 CFR 50.34(b (6)(v) i e
e e
b w
t TSC PRESENT CRITERIA DOCUMENTATION CRGR RE0VIREMENT CHAMGED 1.
Functions:
1.
NUREG-0696 1.
Functions:
- a. Provide plant manage-
- a. Provide plant manage-a.
No ment and technical technical support to support to plant ops.
plant ops. personnel personnel during emergency
- b. Relieve R0's of peripheral
- b. Same as present b.
No duties and communications guidance not related to reactor system-manipulations
- c. Prevent congestion in CR
- c. None c.
Yes
- d. Perform E0F functions for
- d. Same as present d.
No Alert, Site Area and General guidance Emergency Classes until EOF staffed e.
None
- e. Provide technical e.
New support to EOF 2.
Located onsite as close 2.
10 CFR 50 2.
Located witnin pro-2.
Yes possible to CR (within App. E tected ares 2 min walk); perferably
-NUREG-0696 in same bldg.
3.
No major security 3.
NUREG-0696 3.
None 3.
Yes barriers between CR and TSC r
4.
Provisions for safe and
. 4.
NUREG-0696 4.
~None 4.
Yes timely movement between TSC and CR considering effects of direct and airborne radiation 5.
Staffing fully funct ional 5.
NUREG-0696 5.
Staffed by predesignated 5.
Yes in 30 min.
personnel under predesig-nated senior licensee official within 1 hr.
6.
Minimum size for 20 6.
'6.
Large enough size for 6.
Yes nel and NRC and predesignated licensee persog/ person) licensee personnel, 5 NRC ( 75 ft including equipment, equipment and documentation displays and documentation 7.
Space for maintenance, 7.
NUREG-0696 7.
None 7.
Yes repair and servicing equipment
e..
e TSC (continued)
PRESENT CRITERIA DOCUMENTATION CRGR REOUIREMENT CHANGED 8.
Space for personnel to 8.
NUREG-0696 8.
None 8.
Yes access displays data and information 9.
Separa~te room, sized 9.
NUREG-0696 9.
None 9.
Yes for 3 persons for NRC consultations
- 10. Structure must be capable
- 10. NUREG-0696
- 10. Built in accordance
- 10. Yes of withstanding most adverse conditions reasonably expected with National UBC during life of plant
- 11. Radiological habitability
- 11. HUREG-0696
- 11. None
- 11. Yes same as CR-GDC-19; SRP 6.4
- 12. Ventillation requirements
- 12. NUREG-0696
- 12. Normal room air tem-
- 12. Yes same as CR except njl seismic perature, humidity and Category I, redundancy or cleanliness automatic activation (HEPA and charcoal filters called for)
- 13. KI for TSC personnel
- 13. NUREG-0696
- 13. None
- 13. Yes NUREG-0654
- 14. Radiological monitoring
- 14. NUREG-0696
- 14. None
- 14. Yes equipment dedicated to TSC, continuious monitoring for direct radiation and airborne radiciodine and particulates
- 15. Personnel protective
- 15. NUREG-0696
- 15. Radiological protection 15. Yes equipment including in accordance with anticontamination 10 CFR 20 for personnel clothing and respiratory entering, leaving or gear located in the TSC
- 16. Reliable primary and
- 16. NUREG-0696
- 16. Uninterrupted voice
- 16. Yes backup voice communica-10 CFR 50, and hard copy commun-tions including:
ENS; App. E ications with CR and E0F HPN; dedicated telephones and uninterrupted voice to CR, OSC and EOF; tele-with OSC and NRC Ops, phones to access onsite and Center -
offsite locations; communi-cations to monitor teams; State and local gov't E0C's; and 2 telephones for NRC use plus facsimile transmission capability between TSC, EOF and NRC Ops. Center
-~
TSC(continued) i PRESENT CRITERIA DOCU!1ENTATION CRCR REOUIREftENT CHAllGED
- 17. Data system to analyze
- 17. NUREG-0696
- 17. Uninterrupted data
- 17. Yes plant conditions isolated to determine changes from safety systems (GDC 24) in status and forecast backup power supplies and status unavailability goal of 0.01
- 18. Data base is composed of a
- 18. NUREG-0696
- 18. Data base is composed
- 18. Yes parameter set which includes of the reouired variables all the variables in Reg.
in Reg. Guide 1.97 Guide 1.97
- 19. Active data storage to cover 19. NUREG-0696
- 19. None
- 19. Yes 2 hrs. pre-event data and 12 hrs. post-event with retrievable data for 2 wks.
at reduced resolution
- 20. NUREG-0696
- 20. None
- 20. Yes
- 21. Records should include
- 21. NUREG-0696
- 21. Current plant records
- 21. Yes Tech. Specs., Plant Ops, essential for evalua-Procedures, FSAR, Plant tion of emergency Ops. Records, Plant conditions vhich are reactor safety com. records accurate and complete and reports, records needed to perform E0F functions and as-built dwgs. of plant systems which are complete and up-to-date i
k_
i a
-5 o
OPERATIONAL SUPPORT CENTER (OSC)
PRESENT CRITERIA DOCUMENTATION CRGR RE0VIRE!!ENT CHANGED 1.
Functions provides a 1.
HUREG-0696 1.
Provides an area 1.
No location where logistical separate from control support can be coordinated; room where support restricts control. room access personnel will assemble 2.
Located onsite and separate 2.
NUREG-0696 2.
Located onsite 2.
No(11 from control room and TSC
(
3.
Supervised by operations 3.
NUREG-0696 3.
Predesignated licensee 3.
Yes management personnel designated official shall be in emergency plan responsible for coordin-ating and assigning personnel to tasks (this is in CRGR func-tional statement) 4.
No specific habitability 4.
NUREG-0696 4.
No requirement 4.
No criteria 5.
Direct communications with 5.
NUREG-0696 5.
Capable of uninterrupted 5.
Yes (8 control room and TSC; shall voice communications with have 1 dedicated telephone control room, TSC, and EOF extension to control room; 1 dedicated extension to TSC; and 1 dial phone to reach offsite and onsite locations; direct voice communications capabilities may supplement this (1) Basically no change if ;one can assume that the OSC would not be in the TSC (2) CRGR deletes requirement for a dial telephone t,o reach onsite and offsite locations; other than that, there is no change except the CRGR requirement is less prescriptive.
It might, however, be necessary to define " uninterrupted".
If this means a guaranteed 100% availability, then the CRGR requirement could be much more stringent.
e
METEOROLOGICAL DATA REQUIREMENTS PRESENT CRITERIA DOCUMENTATION CRGR REGUIREMENT CHANGED 1.
Control Room iteteorology 1.
10 CFR 50, 1.
Reliable indication of 1.
No Data - Reliable indication App. E meteorological para-of meteorological parameters IV.E.2 meters specified in specified in Reg. Guide 1.97 Reg. Guide 1.97 (wind (wind direction, wind speed direction, wind speed, and stabi',ity) meeting Reg.
and stability) meeting Guide 1.23 specifications Reg. Guide 1.23 specifi-cations 2.
TSC tieteorology Data -
2.
l'ateorological para-2.
Yes l'eteorological parameters App. E meters specified in specified in Reg. Guide 1.97 R. G. 1.97 Reg. Guide 1.97 (wind direction, wind speed, R. G. 1.23 (wind direction, and stability) meeting Reg.
wind speed, and Guide 1.23 specifications for stability) meeting local and regional areas Reg. Guide 1.23 spec-ifications 3.
E0F Peteorolgy Data -
3.
Peteorological para-3.
No Meteorological parameters App. E meters specified in specified in Reg. Guide
.R. G. 1.97 Reg. Guide. 1.97 (wind 1.97 (wind direction, direction, wind speed, wind speed, and stability) and stability) meeting meeting Reg. Guide 1.23 Reg. Guide 1.23 spec-specifications for local ifications for local and and regional areas regional areas 4.
Meteorological system 4.
lieteorological system 4.
Yes availability of.99 availability of.90 or greater or greater s
9 e
NUCLEAR DATA LINK PRESENT CRITERIA DOCUMENTATION CRGR REOUIREMENT CHANGED 1.
Functions:
1.
NUREG-0696 1.
None 1.
Yes The NDL processes and transmits certain reactor process. variables and radio-logical and site meteorological data from an operating nuclear power plant to the NRC Operations Center 2.
Mininum data requirements:
2.
NUREG-0696 2.
None 2.
Yes The data acquisition system has Reg. Guide 1.97 data available to be transmitted to the NRC Operations Center 3.
Implementation Requirements: 3.
NUREG-0696 3.
Data management 3.
Yes The data acquisition system facilities available will provide data to TSC, in the EOF shall include EOF, and SPDS and be the cepability for future available for transmission modification to provide for over NDL transmittal of the data to.
another site 4.
Physical Requirements:
4.
NUREG-0696 4.
None 4.
Yes The NDL and Data Acquisition System must meet envicenmental specifications of TSC.
Power supply shall be high-reliability non-class IE backed by battery.
Data Acquisition System shall have excess capacity and ability'to. expand e
e 4
e
E0F PRESENT CRITERIA DOCUltENTATION CRGR RE0VIREMENT CHANGED 1.
Functions are to:
provide 1.
NUREG-0696 1.
Same except no mention 1.
Yes overall licensee emergency of functioning during response, coordination of radioactive releases radiological and environ-mental ' assessment, decide recommended public protec-tive actions and coordination with Federa'l, State and local agencies and can function during radioactive releases 2.
Facilities should provide 2.
NUREG-0696 2.
Same except only con-2.
Yes for acquisition, display and tainment failure data evaluation of all radiological, on plant systems meteorological and plant system data to detennine offsite pro-tective measures.
Will be used to provide offsite dose projec-tions.
3.
Encourage collocation with 3.
NUREG-0696 3.
None 3.
Yes offsite authorities E
4.
Location nearsite beyond 4.
10 CFR 50 4.
Location within 20 mi.
4.
Yes the site bounda y within App. E of site to facilitate 20 mi. of TSC tu optimize NUREG-0696 interaction with CR, TSC, licensee onsite support Chilk liemo OSC and other personnel and support offsite officials COMJA-80-37 involved in emergency S.
Structure if 10 mi. or 5.
NUREG-0696 5.
Built in accordance with 5.
Yes Chilk Memo national UBC beyond well engineered i
and must meet UBC and
- COMJA-80-37 l
100 yr. winds (other than tornadoes) and fl oods.
If less than 10 mi. must have PF 5 and isolated ventilation with HEPA filters 6.
Size for at least 25 6.
NUR 3-0696 6.
Sufficient to accom-6.
Yes licensee personnel and modate and support d 1 FEt1A Federal, State, local 9 NRC ap/ person) and predesignated
( 75 ft including equipment, licensee personnel, displays and equipnent and documen-documentation -
tation provide space for other Federal, l
State and local officials as needed
r EOF (continued) pRESENT CRITERIA DOCUBIENTATION CRGR RE0VIRE!!ENT CHANGED 7.
Space for maintenance, 7.
UUREG-0696 7.
None 7.
Yes repair and servicing equipment 8.
Space for personnel to 8.
NUREG-0696 8.
None 8.
Yes access displays, data and information 9.
Separate room sized for 5
- 9..NUREG-0695 9.
None 9.
Yes persons for NRC consultations
- 10. Staffing fully functional
- 10. NUREG-0696
- 10. Same
- 10. No within 1 hr.
- 11. Radiological monitoring
- 11. NUREG-0696
- 11. None
- 11. Yes equipment dedicated to E0F, continuious moni-toring for direct radiation and airborne radioiodine and particulates
- 12. None
- 12. -
- 12. Radiological protection 12. New in accordance with 10 CFR 20 for personnel entering, leaving or located in EOF
- 13. Reliable primary and backup 13. NUREG-0696
- 13. Uninterrupted voice
cations with CR, TSC and phones to access onsit'e and off-uninterrupted voice with site locations; communications OSC and NRC Ops. Center to monitoring teams; State and local gov't E0C's and 3 telephones for NRC use plus facsimile trans-mission between TSC, EOF and NRC Ops. Center,
- 14. Data system to analyze
- 14. NUREG-0696
- 14. Uninterrupted data
- 14. Yes plant conditions isolated to determine changes from safety systems (GDC 24) in status and forecast backup power supplies and status unavailability goal of 0.01
- 15. Data base is composed of a
- 15. NUREG-0696
- 15. Data base is composed
- 15. Yes parameter set which includes of appro ariate variables all the variables in Reg.
in Reg. Guide 1.97 Guide 1.97
.w
- 10 _
E0F (continued)
PRESENT CRITERIA DOCUMENTATION CRGR REOUIREMENTS CHANGED
- 16. Active data storage to cover 16. HUREG-0696
- 16. None
- 16. Yes 2 hrs. pre-event data and 12 hrs. post-event with retrievable data for 2 wks.
at reduced resolution
- 17. NUREG-0696
- 17. None
- 17. Yes
- 18. Records access should
- 18. NUREG-0696
- 18. Have access to current
- 18. Yes include Tech. Specs., plant plant records, procedures I
ops. procedures, emergency ops, and emergency plans for procedures, FSAR, up-to-date E0F functions records related to licensee, State and local emergency plans, offsite population, evacuation plans, environs rad.
monitoring records, employee rad.
exposure records and drugs, schematics and disgrams showing plant systems, structures and locations which are complete and up-to-date
- 19. If located within 10 mi. of 19. NUREG-0696
- 19. None
?
e 9
e
_____ _