ML20040E907
| ML20040E907 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1981 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| TASK-IC-121-5, TASK-RE ACRS-1909, NUDOCS 8202080062 | |
| Download: ML20040E907 (14) | |
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1 A7C M -/709 \\
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DATE ISSUED:
11/13/81 T_._.J I
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MINUTES OF THE ACRS SUBC04MITTEE MEETING ON REGULATORY ACTIVITIES liff'I fl OCTOBER 14, 1981 WASHINGTON, D.C.
INTRODUCTION The ACRS 'iubcommittee on Regulatory Activities held a meeting on October 14, 1981, at 1717 H Street, N.W., Washington, D.C.
The entire meeting was open to public attendance. Mr. Sam Duraiswamy was the Designated Federal Employee for the meeting.
A list of documents submitted to the Subcommittee is included in Attachment A.
ATTENDEES ACRS:
C. P. Siess (Subcommittee Chairman), M. Bender, J. J. Ray, M. W. Carbon, D. A. Ward, W. M. Mathis, D. W. Moeller, S. Duraiswamy (Designated Federal Employee)
Principal NRC Speakers:
W. Morrison, W. Anderson, E. Wenzinger, C. Schulton, A. Taboada, B. Zalcman, L. Brown, L. Beratan, R. Kornasiewicz, I. Spickler, S. Ramos.
EXECUTIVE SESSION Dr. Siess, the Subcommittee Chairman, convened the meeting at 8:45 a.m. and reviewed briefly the schedule for the meetir,g, indicating that the Subcommittee will hold discussions with the NRC Staff on the following items:
1.
Regulatory Guide 1.23, Revision 1, " Meteorological Programs in Support of Nuclear Power Plants" (post comment).
2.
Proposed Amendment to 10 CFR Part 50, Section 50.55a, " Codes and Standards" (pre comment).
3.
Regulatory Guide 1.13, Revision 2, " Spent Fuel Storage Facility Design Basis" (pre comment).
4.
Proposed Regulatory Guide (Task No. IC 121-5), " Response Time Testing of Protection System Instrument Channels" (pre comment).
l In addition to the above items, the Subcommittee will discuss also a proposal that was made by Mr. Bender for an abbreviated Safety Analysis Report for ACRS use. He said that the Subcommittee had received neither written comments nor requests for time to make oral statements from members of public.
8202080062 811113 l
1909 PDR
Regulatory Activities October 14, 1981 REGULATORY GUIDE 1.23, REVISION 1, " METEOROLOGICAL PROGRAMS IN SUPPORT OF NUCLEAR POWER PLANTS" (POST COMMENT)
Ms. Brown reviewed this Guide brielfy, indicating that it describes meteoro-logical measurement programs for obtaining meteorological data needed to estimate potential radiation doses to the public resulting from actual j
routine or accidental releases of radioactive materials to the atmosphere or to evaluate the potential dose to the public as a result of hypothetical reactor accidents.
The proposed revision to this Guide reflects current state of the art in meteorological technology and also accommodates the lessons learned from the TMI-2 accident concerning meteorological measure-ment programs at nuclear power plant sites.
It provides also better guidance concerning measurement of meteorological parameters, location of instruments to measure these parameters, maintenance and servicing of instruments, etc.
The major changes between this revision and Safety Guide 23 are that the current version provides additional guidance on meteorological programs that apply to operating nuclear power plants; it includes additions to meteorological instru-ments, chiefly to meet the need for emergency prepardeness and emergency manage-ment.
A previous version of this Guide was reviewed by the Regulatory Activities Subcommittee during the June 4,1980 meeting and was issued for public comment l
on September 20, 1980.
This current version rc?lects consideration of public l
comments.
Ms. Brown discussed the n6ture of public comments received on this Guide during its public comment period and the changes made to it as a result of the resolution of those comments.
She said that the NRC Staff had received 229 comments from about 31 commentors representing utilities, consulting and architect-engineer firms and some government agencies.
Ms. Brown stated that some of the commentors expressed concern indicating that the general guidance of this Guide will not be useful for sites with unique features.
As a result, the NRC Staff has included more flexibility in this Guide so that it could be applied to sites with special features.
Regulatory Activities October 14, 1981 She said that in view of the unavailability of one single system for measur-ing atmospheric stability, coupled with the limitr:f on: of the AT (vertical temperature difference) method recognized by the netsorological society, they have included in this Guide other indicators to determine atmospheric stability.
Ms. Brown pointed out that some of the commentors have expressed concern about the new requirements added in this Guide. She believes that it does not include additional requirements in the preoperational meteorological program area. Most of the new requirements in this Guide resulted from incorporating changes in regulations, especially in the emergency preparedness area.
Ms. Brown said that as a result of public comments, the Value-Impact Statement of this Guide has been expanded to orovide cost estimates for complying with the provisions.of this Guide.
For a nuclear plant which does not have any meteorological measurement program, the total estimated cost of purchasing, locating and installing the necessary equipment to meet the recommendations of this Guide may range from $250,000 to $500,000 depending on the complexity of the site. For those who already have meteorological programs and need to purchase and install only certain equipment for remote access capability to l
obtain meteorological data for emergency response purposes, the estimated cost may he between $20,000 and $30,000.
With reference to the comments provided by Mr. Higginbotham, Chief, Radiological Safety Branch, Inspection and Enforcement (I&E) Office of NRC, in his letters dated November 14, 1980 and January 26,1981 ( Attachment B), Dr. Siess commented that it does not seem appropriate to handle internal comments along with other public comments.
There should be some process. of reviewing internal comments prior to issuing a Guide for public comment.
He asked about the coordint Mon between the Office that is responsible, for developing a Guide and the Office that is responsible for enforcing the provisions of that Guide.
l Mr. Beratan responded that prior to issuing this Guide for public comment, they 1
had coordinated with the Office of Nuclear Reactor Regulation (NRR) and I&E.
He believes that the primary user of this Guide in I&E is the Emergency Prepared-ness Branch and not the Radiological Safety Branch, headed by Mr. Higginbotham.
Regulatory Activities October 14, 1981 In any event, as soon as they received comments from Mr. Higginbotham, they met with him and tried to resolve his comments.
Based on the discussion, they thought the concerns expressed by Mr. Higginbotham were taken care of.
Dr. Siess commented that, since one of the objectives of this Guide is to provide information for determining the radiation doses to the public resulting from routine releases', he thinks that the Radiological Safety Branch, headed by Mr. Higginbotham, is also one of the primary users of this Guide. Mr. Kornasiewicz responsed that, although this Guide is used by both the Radiological Safety and the Emergency Preparedness Branches of I&E, the revisions and the new require-ments of this Guide relate primarily to the need for emergency preparedness and not for routine releases.
The portion of this Guide to be used for routine release dose calculations remains unchanged with the exception that it has been clarified somewhat.
Dr. Siess asked how much meteorological information of the kind that could be obtained from the sophisticated systems called for in this Guide entered into certain emergency decisions, such as the need for evacuation, during the TMI-2 accident.
The NRC Staff responded that, during the TMI-2 accident, necessary meteorological information was made available for use in the decision-making process.
However, they are not sure how that information was factored into the decisions.
Dr. Siess commented that there is no question that meteorological information could be useful under certain circumstances.
However, he has serious doubts whether such information is going to be used to make emergency decisions during an incident.
l l
Mr. Bender commented that the NRC Staff's attempt to provide guidance in this l
Guide for both normal and emergency operating conditions is confusing and need:
i additional clarifiation.
The point that a realistic approach needs to be used
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to assess meteorological conditions in a real emergency, and a conservative approach may be used for the evaluation of a site, is not made clear.
Consider-ing the fact that in a real emergency one has very little time to boil down
Regulatory Activities October 14, 1981 information to a very few basic things that could be communicated to people who are riot familiar with meteorological problems, the NRC Staff needs to put additional effort to clarify the application of this Guide for various situations.
In his opinion, it would have been better if this Guide dealt with only one issue, either normal condition or emergency situation.
- However, since it may be too late, it would be helpful to include, in the " Discussion" Section of this Guide, a better discussion of the NRC Staff's philosophy under which this Guide is developed.
Mr. Zalcman responded that this Guide mainly deals with meteorological instru-mentation and does not deal with the use of meteorological data.
Dr. Siess commented that if this Guide deals only with meteorological instru-mentation, then the title of this Guide should be changed to reflect that point.
The NRC Staff agreed to change the title of this Guide from " Meteorological Program in Support of Nuclear Power Plants" to " Meteorological Measurement Programs for Nuclear Power Plants".
Dr. Siess commented that the phrase "will receive consideration", in one of the statements of the Implementation Section which states " Construction permit and operating license applications docketed prior to January 1984 will receive consideration.......... when the data collection period commenced.", does not describe clearly the NRC Staff's intention.
He suggested that some clarification to make the NRC Staff's intent clearer would be helpful.
Dr. Moeller agreed with Dr. Siess that the Implementation Section needs additional clarification.
Ms. Brown and Mr. Berantan agreed to make appropriate changes.
Mr. Bender commented, considering the fact that the source term is not defined well, he is not sure how an improved meteorological data base will help improve our understanding of the accident contingencies and the evacuation process.
He is bothered by the lack of adequate integration between the source-term data and meteorological data.
He believes that the NRC Staff is asking for too much
t Regulatory Activities October 14, 1981 meteorological data.
He is doubtful that the more sophisticated meteorological system required in this Guide, which is expected to cost about $250,000 to
$500,000 for some plants, and the additional meteorological data expected of such a system will add that much to the ability to deal with an accident.
Dr. Siess commented that, in view of the fact that we start off with an arbitrary source term and end up with an arbitrary dose rate, he is not sure whether there is a need for a more accurate meteorological data base.
Mr. Zalcman responded that there has been adequate integration between source term data and meteorological data; it is the integration of the source-term data with meteorological data that yields the dose rate. Mr. Spickler added that all of the meteorological instrumentation required by this Guide is commerically available.
He feels strongly that the meteorological data required by this Guide are necessary to have a good feel for the diffusion characteristics during normal and accident conditions and also to determine the implications. The cost estimate of $250,000 to $500,000 specified in this Guide applies to plants that do not now have any meteorological system. He believes that about two-thirds of the plants already have the primary meteorological system and thus have the cap-ability to obtain most of the meteorological data required by this Guide; however, those plants may need to install backup and supplemental systems, primarily consisting of 10-meter masts with limited instrumentation and telemetry, and such systems are estimated to cost about $20,000 to $30,000.
l With reference to the comments from Stone & Webster and Consumer Power Company l
which state that the cost of backup and supplemental meteorological data collection systems will run into hundreds of thousands of dollars for each plant site, Dr. Carbon commented that there seems to be a major difference between the cost estimate specified in this Gaide and that specified by these two companies.
He sought clarification for tSis significant difference in cost estimates for the backup and supplemental systems. Messrs. Zalcman and Spickler responded that based on their experience, they do not believe that the estimate provided by Stone & Webster and Consumer Power Company represent a ealistic estimate.
Regulatory Activities October 14, 1981 Mr. Ray pointed out some duplication of sentences in certain parts of this Guide that the NRC Staff agreed to take care of.
With regard to the terminology " gaseous effluents" used in this Guide, Dr. Moeller commented that it would be better to use the terminology " airborne effluents" since it includes gaseous as well as particulates.
The NRC Staff agreed to use the terminology " airborne effluents" in places of" gaseous e f fl uents".
Regarding the title " Siting of Meteorological Instruments" of Regulatory Position C.2, Dr. Moeller commented that the word " siting" in this title is confusing.
He suggested that the word " siting" be changed to " Location".
Mr. Zalcman responded that since the word " siting" in Position C.2 deals with something other than location, they prefer to use it instead of the word
" Location".
Dr. Siess commented that most of the infor~ition included in the Value-Impact Statement is outdated.
The Value-Impact assessment in this Guide applies to the development of this Guide. However, since the Guide has already been developed, the Value-Impact assessment should have been on the promulgation of this Guide.
Dr. Siess commented that the " Discussion" Section of this Guide is somwhat unique; it does not relate to the Regulatory Position like other Guides do.
He suggested that it would be helpful if it included some information on the need for the proposed revision and how it differs from the origiani version of this Guide.
He said that in the future when submitting a revised Guide to the ACRS for review, it would be helpful if the NRC Staff included a brief state-ment of what the revisions are and why they are being made.
Mr. Bender commented that he is uncomfortable with the application of this Guide for emergency conditions.
It is not at all clea. 50w this Guide applies
Regulatory Activities October 14, 1981 to the emergency situation.
He suggested that including some information in the " Discussion" Section to differentiate clearly the application of this Guide for emergency situations and for other purposes would be helpful.
It would also be better to include some of the information provided in the " Discussion" Section in tn Appendix to this Guide.
Mr. Beratan said that they will modify the " Discussion" Section, as appropriate,
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and try to incorporate the suggestions provided by Dr. Siess and Mr. Bender.
Indicating that it would be better if the NRC Staff revised this Guide incor-porating the suggestions provided by the Subcommittee and agreed to by the NRC Staff and resubmit it to the Subcommittee for further consideration, Dr. Siess asked the opinions of the Subcommittee members.
Mr. Bender commented that the main scope of this Guide is not made clear.
This Guide seems to put its emphasis on the improvement of the accuracy of meteorological data base rather than on having certain amount of meteorological instruments that are necessary to obtain data during an emergency. He believes that this Guide needs additional improvement; it would benefit from another revision and possibly even another review by members of the public. He added that this Guide is not consistent with *.he Administration's policy of trying to avoid over-regulation in places where it is unimportant and the ACRS should keep this in mind when reviewing documents such as this one.
With reference to the concerns expressed by Mr. Higginbotham, Office of the I&E of NRC, Dr. Carbon commented that he has serious reservations in approving l
this Guide in its present form without exploring the concerns of Mr. Higginbotham.
Mr. Wigginton representing the Office of I&E said that although he agrees that this Guide may help improve the meteorological measurement programs, he does l
not believe that the improvement is. worth the money.
In view of the uncertain-l ties associated with the source term, he does not believe that such a sophisti-cated meteorological program is necessary.
Regulatory Activitics October 14, 1981 Dr. Siess commented that there seems to be some misunderstanding of the exact requirements of'this Guide. He suggested that a comparative discussion of the contents of Revision 1 with Revision 0 of this Guide would be helpful to the Subcommittee to have a clear perspective of the changes made in Revision 1.
In compiling that comparative list, it would also be helpful if the NRC Staff identified the significant changes between Revision 1 and Revision 0 of this Guide along with the ' reasons for those changes.
The Subcommittee indicated that the NRC Staff revise this Guide incorporating the suggestions and comments provided by the Subcommittee and agreed to by the NRC Staff and resubmit it to the Subcommittee for further consideration at the meeting tentatively scheduled to be held on November 11, 1981.
PROPOSED AMEND. MENT T010 CFR PART 50, SECTION 50.55a, " CODES AND STANDARDS" (PRE COMMENT)
The Proposed Amendment to 10 CFR Part 50, Section 50.55a is to incorporate by reference parts of Section III of the ASME Boiler and Pressure Vessel Code that apply to Class 2 and 3 components.
Also, it would clarify and modify the existing provision in Section 50.55a that deals with the procedures for establishing acceptable alternatives to the referenced ASME Code; it would delete also an absolete exemption to the ASME Code that the Code N-Symbol need l
l not he applied to components constructed to the requirements of the Code.
l l
Dr. Siess said that this proposed Amendment to 10 CFR 50.55a was reviewed by Dr. Bush, ACRS consultant, and with the exception of some trivial comments he did not have any major problems.
A copy of Dr. Bush's comments is included in Attachment C.
The NRC Staff pointed out that since the information in Regulatory Guide 1.26 has been incorporated into the Proposed Amendment, they plan to withdraw that Guide. The Subcommittee did not object.
The Subcommittee indicated that the NRC Staff could issue this for public comment.
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1 l
Regu t atory Activities October 14, 1981 The Subcommittee suggested that it would be helpful if the Metal Components Subcommittee of the ACRS reviewed this Guide during its public comment period and provide its comments to the Regulatory Activities Subcommittee.
PROPOSED REGULATORY GUIDE 1.13, REVISION 2, " SPENT FUEL STORAGE FACILITY DESIGN BASIS" (PRE COMMENT)
Regulatory Guide 1.13, Revision 2 describes a method for implementing General Design Criterion 61, " Fuel Storage and Handling, and Radioactivity Control,"
which requires that fuel storage and handling systems should be designed to assure adequate safety under normal and postulated accident conditions.
It endorses, with certain exceptions, ANSI N210-1976/ANS 57.2, " Design Objectives for Light Water Reactor Spent Fuel Storage Facilities at Nuclear Power Station".
It incorporates also certain modifications to be consistent with NUREG-0612,
" Control of Heavy Loads at Nuclear Power Plants" and revised Standard Review Plan (SRP) 9.l'.4, " Light Load Fuel Handling Systems".
Dr. Siess commented that this Guide is not well organized and needs editing.
Further, the " Discussion" Section of this Guide does not have a one-to-one relationship to the Positions.
He suggested that some modifications and re-arrangements would be helpful.
With regard to Regulatory Position C.1, Dr. Siess commented that it is not made clear as to why the example in Section 4.2.4.3(1) of the ANSI N 210-1976 Standard should be modified; the kind of exception taken to Section 4.2.4.3(1) of the Standard should be made clear. He said that it is somewhat misleading and suggested that some modificaitons would be helpful. The NRC Staff agreed to make appropriate changes.
Regarding Regulatory Position C.4, Dr. Siess commented that the last sentence of this Position, which states "In the event an earthquake or a tornado missile damaged both the fuel pool containment and the fuel pool cooling system, no credit can be given to the filtration system used to reduce the amount of radioactivity,"
does not seem to impose any requirement and suggested that it may be better to delete this sentence. The NRC Staff agreed to this suggestion.
Dr. Siess commented t%t Regulatory Position C.5 needs some clarification as to how the non-fuel components get radiated.
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Regulatory Activities October 14, 1981 U
With regard to the maximum operating temperature limit of 60 C specified under Case II in Regulatory Position C.10, Mr. Bender commented that this temperature limit may not apply to all of the resin types. He suggested that instead of specifying a temperature, it is better to say that the maximum operating temperature limit should be such that there will be no degradation and let the designer of the system establish the proper temperature.
Mr. Mathis commented that it is not clear to him why pool boiling is permitted only in Case IV in Regulatory Position C.10 and not in some other cases. Mr. Steir responded that since it is an extreme case unaet abnormal situation, pool boiling is permitted.
Dr. Siess commented that it seems that some intermediate abnormal cases are not listed in Regulatory Position C.10.
One such case may be losing both cooling loops during normal refueling when the pool is full of spent fuel; if Case IV under Regulatory Position C.10 is modified to permit pool boiling for this situation, then one could assume that boiling would be permitted for the extreme (full core offload) case.
Mr. Bender suggested that it would be helpful to include in the Discussion Section of this Guide the rationale for permitting pool boiling and the conse-quences there of.
Mr. Ward commented that paragraphs 3.3 and 3.4 of Annex A to this Guide are not clear and need additional clarification. The NRC Staff said that they plan to rewrite these sections.
Dr. Siess commented that the Value-Impact Statement needs to be updated._
After further discussion, the Subcommittee indicated that the NRC Staff could issue this Guide for public comment.
PROPOSED REGULATORY GUIDE (TASK NO. IC 121-5), " RESPONSE TIME TESTING OF PROTECTION SYSTEM INSTRUMENT CHANNELS" (PRE COMMENT)
This Guide provides guidance for testing instrument channels of protection systems to determine response time characteristics in order that the degra-
Regulatory Activities October 14, 1981 dation in performance of instrument channels can be detected and maintained properly to keep' the channels within acceptable limits.
It endorses, with certain exceptions, Instrument Society of American (ISA) Draft Standard ISA-d5 67.06, " Response Time Testing of Nuclear-Safety-Related Instrument Channels in Nuclear Power Plants," dated October 21, 1980.
Dr. Siess asked why, since the Draft ISA Standard endorsed by this Guide may get changed before it becomes final, do they want to issue this Guide at this time? Mr. Wenzinger responded that they have approval from the ISA Committee to endorse the draft Standard in this Guide. Further, he does not believe that there will be many significant changes before it becomes final.
Dr. Siess commented that the " Discussion" Section of this Guide should be limited to its main scope; since structures are not handled in this Guide, there is no need to specify structures in this Section. The NRC Staff agreed to make appropriate changes.
Dr. Siess commented that the sentence in Regulatory Position C.2 which states "The recommendation that an evaluation be made to determine if calibration adjustments could effect the response time should be treated as a requirement" does not seem to represent the intent of the NRC Staff and it needs to be fixed.
He added that the NRC Staff's intent is also not made clear in Regulatory Position C.3. He suggested that certain changes would be helpful.
After further discussion, the Subcommittee indicated that the NRC Staff could issue this Guide for public comment.
The Subcommittee suggested that it would be helpful if the Electrical Systems Subcom;ittee of the ACRS reviewed this Guide during the public comment period and provide its comments to the Regulatory Activities Subcommittee.
DISCUSSION OF MR. BENDER'S PROPOSAL FOR A CONDENSED SAFETY ANALYSIS REPORT The Subcommittee discussed the proposal for a condensed Safety Analysis Repoort (SAR) made by Mr. Bender in his letter to Mr. R. Fraley, dated April 13, 1981.
Regulatory Activities October 14, 1981 Mr. Bender said that since an SAR in its present form is very buhy and hard to carry around, coupled with the fact that most of the information in the SAR is academic, he believes strongly that it would be helpful to the ACRS to have a condensed SAR that would include a brief description of at least the plant, containment, important emergency systems, and some important technical specifica-tions.
It would be helpful also to include in that report some simple schematic diagrams of the systems.
After discussion, the Subcommittee decided to recommend the following to the full Committee:
1.
A condensed SAR may be useful to the ACRS.
However, as a first step, someone should develop a format for that report.
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2.
A pilot program along this line should be undertaken either by the ACRS Staff or ACRS Fellows or outside Consultants to prepare such a report for one pl ant.
FUTURE MEETING:
The next ACRS meeting is scheduled to be held on November 11, 1981 to discuss
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the revised version of Regulatory Guide 1.23, Revision 1, " Meteorological Measurement Programs For Nuclear Power Plants".
l Dr. Siess thanked all participants and adjourried the meeting at 1:10 p.m.
NOTE: Additional meeting details can be obtained from a transcript of this l
meeting available in the NRC Public Document Room,1717 H Street, N.W.,
Washington, D.C., or can be purchased from Alderson Reporting Company, Inc., 400 Virginia Avenue, S.W., Washington, D.C. 20024, (202) 554-2345.
I l
Regislatory Activities Meeting 10/14/81 i
LIST OF DOCUMENTS SUBMITTED TO THE SUBCOMMITTEE 1.
Regulatory Guide 1.23, Revision 1, " Meteorological Programs in Support of Nuclear Power Plants" (post comment).
2.
Proposed Amendment to 10 CFR Part 50, Section 50.55a, " Codes and Standards" (pre connent).
3.
Regulatory Guide 1.13, Revision 2, " Spent Fuel Storage Facility Design Basis" (pre comment).
4.
Proposed Regulatory Guide (Task IC 121-5), " Response Time Testing of Protection System Instrument Channels" (pre comment).
5.
Proposal by Mr. Bender for a condensed Safety Analysis Report included in his letter to R. Fraley, dated April 13, 1981.
ATTACHMENT A
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SSINS: 9300 S(6..'4' ROV 14 1980
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MEMORANDUM FOR:
K. R. Goller Director Division of Siting Health and Safeguards Standards, OSD FROM:
Leo B. Higginbotham, Chief, Radiological Safety Branch IE
SUBJECT:
C0' GENTS ON PROPOSED REVISION 1 TO REGULATORY GUIDE 1.23, HETEOR0 LOGICAL PROGRAMS IN SUPPORT OF NUCLEAR POWER PLANTS y-/ 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.
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 3
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 t
on the potential for significant releases of radioactivity, with potential doses being based on default 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 equi more importance for the actual dose calculational process. pment, which is of l
Overall, the tone of the proposed revision strikes us cs 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 confimation of meteorological 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 health and safety should be looked at and balanced w
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y 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 g4
$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-thougnt, with due consideration given to the other re:;uirements being imposed to increase safety.
sQ A a E Leo B. Higg Chief, Radiological Safety Branch Division of Safeguards and Radiological Safety Inspection, IE cc:
H. D. Thornburg B. Grimes W. Kreger Stew Bland Jim Wi ginton 28188 l
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MEMORANDUM FOR: Karl R. Go11er Director, Division of Siting Health and Safeguards Standards FROM:
Leo B. Higginbotham, Chief, Radiological Safety Branch, IE
SUBJECT:
REVISION 1 TO REGULATORY GUIDE 1.23 f
i
Reference:
Pty memo to you dated 11/14/80 l
l The purpose of this memorandum is to clarify the coments and purpose of sy previous memorandum.
Steve Ramos will be sending you a memo on the proposed revision to Regulatory Guide 1.23 discussing a couple of meetings of his and sty, staff and requesting that the revised guide be published. I have no objection to Steve's memorandum and I do not, nor does sty staff, have any objection to the publication of the revision to the guide.
f/ / The thrust of my November 14 memorandum was that the guide specified design criteria for meteorological ecuipment and programs that we thought were excessive and perhaps should be reviewec and reconsidered. We still believe some of the j
criteria and specifications are overdrawn and unneessary for the intended purpose of meteorological programs. If the staff concensus, however, is that they art indeed required, then I suppose we hold the minority opinion.
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Leo B. Hi tham Chief j
Radiological Safety Branch, IE cc:
S. Ramos S. Bland J. Wigginton i
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~/y ATTacHM6t4T 6
OBattelle Pacific Northwest Laboratories P.O. Box 999 Richland, Washington U.s.A. 99352 October 2,1981 Telephone (5093 375-2223 Telex 15-2874 Mr. Sam Duraiswamy Staff Engineer U.S. Nuclear Regulatory Comission Advisory Comittee on Reactor Safeguards Washington, D.C.
20555
Dear Sam:
Generally the changes are housekeeping. The incorporation of Class 2 and 3 picks up items in R.G. 1.26 and is a good idea. Most of my coments are aimed at trivia; however, they should be cleaned up.
It would be better to reex'mine this section after the modifications pertinent a
to ASME XI are incorporated.
I cannot establish the status of footnote?
Neither can I determine whether items (h), (1) and (j) are to be changed.
I note that (i) cited in old (a)(2) is not cited in new (a)(2).
Is this because of handling in appendices or what?
(a)(2) Coverage essentially same.
(a)(3) Basically replaced (a)(i) (a)(ii).
(b)
Probably reserved for ASME XI.
(c)(1) Footnote (3) should be dropped.
It has been deleted and number reserved.
(c)(2) Old footnote (2); only significant change is makeup oeprable from on-site emergency power. This is required in any event.
(c)(3) Footnote (6) refers to a paragraph now deleted; namely (a)(2)(ii)
I needs revision. Old (b)(1) cites applicability of editions and j
addenda; e.g. 1977 edition.
l (c)(4) Covered in a variety of paragraphs re various acceptance dates.
l (d)
New (d)(1) First para raph makes class 2 by virtue of isolability; (i),
(ii), (iii, (iv), (v) covered in R.G.1.26.
Items (vi), (vii),
(viii) covers new ground and is an upgrade.
Footnote (9) - OK)
Note that vi, vii, viii cover new ground.
Presumably ACRS has accepted the upgrade in the past. These reprebent a recognition of the safety functions of the systems.
(d)(2) Excluded by virtue of isolation.
Same philosophy vis-a-vis Class 1 to Class 2.
/
h7YRC$fh16hlT 0 4
p
r NHelle S. Duraiswamy October 2, 1981
~
Page - 2 (d)(3) ' Acceptability c# rditicns and addenda.
(e)
Class 3 components (e)(1.) Defines scope of Class 3 by exception. This as written is somewhat ambiguous, e.g., not part of RCPB; owever, or refinery h
to Class 2 can be inferred to include. Would neither in p7 ace of not or nor in place of or be clearer.
sentence is a caveat that could be moved to (per (e)(1).
Parts of system such as ECCS but excluded Last (e)(1)(1) e)(1)sinceitis a subset.
(e)(1)(ii) OK - also in R.G. 1.26.
(e)(1)(iii) This applies equally to Class 2 system and does not define Class 3 systems.
I cannot determine what is to be accomplished.
Taken separately it serves no purpose.
It should be clarified.
(e)(1(iv) Standard out of R.G. 1.26.
I believe footnote 10 is lifted our of R.G.1.26.
(e)(1)(v) Exchanger (spelling).
R.G. 1.26 (e)(1)(vi) Stcndcrd (e)(2) Same as (d)(3)
Footnotes (1) OK j,
5 (2) Deleted 3
(3) Deleted (4) OK 6
(5) OK (6) See note re revision (7) Revised?
Very truly yours, W
Spencer H. Bu'sh Senior Staff Consultant SHB/ par Attachment h_
0 T