ML20127H288
| ML20127H288 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1421, NUDOCS 8506260280 | |
| Download: ML20127H288 (111) | |
Text
.
ORIGINAL UNITED STATES OF.AMEF.ICA ex NUCLEAR REGULATORY COMMISSION In the matter of:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS Subcommittees on Waste Management and Site Evaluation Docket No.
Location:
Washington, D. C.
Pages: 238 - 302 Date:
Wednesday, June 19, 1985 ANN RILEY & ASSOCIATES Court Reporters
~
1625 I St., N.W.
Suite 921
/\\
Washington, D.C.
20006
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(202) 293-3950
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8506260280 850619 PDR ACRS T-1427 PDR
.Jon'Walsh 238 UNITED STATES OF AMERICA 3
NUCLEAR REGULATORY COMMISSION
(
2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
4 5
Subcommittees on Waste Management and Site Evaluation 6-4 7
8 Nuclear Regulatory Commission 1717 H Street, N. W.
9 Room 1167 Washington, D.
C.
10 Wednesday, June 19, 1985 11 12 The meeting of the Subcommittee on Waste
. 13 Management / Site Evaluation reconvened at 8:30 a.m.,
14 D. W. Moeller, Chairman of the Subcommittee, presiding.
15 PRESENT FOR THE ACRS SUBCOMMITTEE :
16 D. W. Moeller, Chairman Robert C. Axtmann 17 Max W. Carbon 18 ALSO PRESENT:
19 F. Parker K. Krauskopf 20 R.
Foster O. Merrill 21 S. McGuire D. Rohrer 22 R, Cardarelli 23 24 O
25
1 239 1 - Joe Watis)
P_ E 9,Q E E D,I.,E g Q 2
(8:30 a.m.)
3 MR. MOELLER:
The meeting will now come to 4
order.
5 This is a continuation of the open meeting of 6
the combined ACRS Subcommittees on Waste Management / Site 7
Evaluation.-
8 I am Dave Moeller, Chairman of~the two sub-9 committees.
The other ACRS member present at the moment 10 is Max Carbon, and we anticipate that Robert Axtmann will 11 join us shortly.
12 We have three ACRS consultants with us; Frank 13 Parker, Konrad Krauskopf, and Richard Foster.
14 The purpose of the meeting is to continue the 15 reviews that we had begun yesterday of the various documents, 16 and the one that we want specifically to review this morning 17 is the report -- the proposed rule on emergency preparedness 18 for fuel cycle and other radioactive material licensees.
19 This is 10 CFR 30, 40, and 70.
20 Seated on my right is Owen Merrill, who is the 21 itssigned ACRS Staff Member for this meeting.
22 A transcript of the meeting is being kept, and it 23 is requested that each speaker first identify himself or herself 24
,and speak with sufficient clarity and volume so that he or she O
25 can be readily heard.
2.
240 1
We have received no written statements from (O) 2 members of the public, and we have received no request for 3
time to make oral statements, but if there is any member of 4
the public here who would like to comment later in the day, 5
check either with Owen Merrill or with me and we will try 6
to accommodate you.
7 We will, after the formal presentations and 8
discussion this morning, we will then go into an executive 9
session, but the executive session will continue in open 10 session, and anyone who desires to stay is certainly welcome 11 to do so.
12 During the executive session, we will prepare C')
any appropriate written comments that we may want to forward 13 d
14 to the full committee on the proposed rule that we are 15 discussing this morning, and the subcommittee also plans to 16 prepare written comments on the proposed EPA standards for 17 high level waste repository.
They are 40 CFR 191.
18 We will now -- well, let me ask.
Do any of the 19 consultants, or Max, do you have any remarks at this time?
20 (No response.)
21 Okay.
We will proceed with the meeting, and I 22 will call upon Doctor Stephen McGuire to open with the 23 discussion of the proposed rule on emergency preparedness.
24 Stephen?
25 MR. McGUIRE:
Good morning, Dave.
3 - Joe Walsh 241 1
MR. MOELLER:
Good morning.
rS
(_)
2 MR. McGUIRE :
Good to see you again.
I would 3
like to pass out a copy of the viewgraphs if you would like.
4 Take one of those.
5 (Documents passed to all present.)
6 In addition, we have a slightly revised version
-7 of the Regulation.
8 MR. MOELLER:
All right.
9 MR. McGUIRE :
I think substantively, it isn't to really changed from what you had received earlier, but 11 the words are slightly different, so I will also -- well, 12 I will leave this for you.
. ('
13 (Document passed to all present.)
-14 MR. MOELLER:
And you will tell us estimated 15 schedule on this?
16 MR. McGUIRE:
Yes.
17 MR. MOELLER:
Okay.
18 MR. McGUIRE:
Now, I will first give you just 19 a little bit of background, and TMI, of course, is the 20 starting point for this whole thing.
21 In 1980, the Commission asked the Staff to 22 consider the need for additional emergency preparedless at 23 fuel cycle and material licensees.
24 The staff looked at that, the NMSS Staff, and
,S i,j 25 decided that there should be more emergency preparedness
242 4-Jon Walsh 1
than there was at that time, and in 1981 they issued
.k_)g 2
orders ordering certain large facilities to submit emergency 3
plans that met certain criteria that they established, and 4
in addition, advance notice of proposed rulemaking was 5
issued, that basically codified the orders.
6 The proposed rule you have now essentially 7
codifies those orders with some modifications.
8 Now, this proposed rule, as it stands now, 9
would effect approximately sixty licensees.
We estimate 10 that some of them would lower their possession limits, 11 about fifteen.
12 These are generally broad licensees who have 13 licenses that at the moment state that they may possess 14 something like any isotobe atomic number 3 through 83, 15 ten curries each, and they are being caught by the low 16 numbers for a few specific isotobes; usually Iodine 131.
17 And since these we don't expect to have any 18 use for that amount of iodine by merely rephrasing their 19 possession limits, they would not be affected by the 20 license -- by the requirement.
21 MR. CARBON:
Steve?
22 MR. McGUIRE:
Yes.
How was this fuel cycle facility 24 made?
25 MR. McGUIRE:
This includes potentially uranium
{
5 - Joe Wal 243 1
mills, UF-6 production facilities, fuel fabrication plants,
(,/
2 spent fuel storage, and waste processing.
Doesn' t spent fuel storage on 4
the nuclear power plant?
5 MR. McGUIRE:
No.
6' MR. CARBON:
Totally separate.
7 MR. McGUIRE:
That would be -- really the power 8
plant has the requirements of Part 50 for the power plant, 9
so that is so much more than you would need for the other 10 small amounts that you get out of the spent fuel storage.
11 It is more than adequate.
12 MR. MOELLER:
Now, it also, though, covers radio f~')
13 nuclide commerical users, like radio pharmaceutical.
V 14 MR. McGUIRE:
This rule will cover that, yes.
15 I was just mentioning what was in the fuel cycle.
16 MR. MOELLER:
Oh, I am sorry.
Okay.
Because 17 it has:
And other things.
18 MR. CARBON:
What else will it cover?
What 19 you mentioned, what Dave mentioned, and what else?
20 MR. McGUIRE:
Yes.
It would be fuel cycle is 21 the one, and the other is certain large byproduct materic.
22 licensees.
23 MR. CARBON:
University?
24 MR. McGUIRE:
Potentially, a university would C/.)
25 be covered, but in a screening analysis that we did, we do
6 - JW 244 1
not believe that any universities would be covered.
.(m}
2 The ones it tends to cover in the byproduct 3
material licensees, are radio pharmaceutical manufacturers 4
and seal source manufacturers, and certain large research 5
facilities.
6 MR. MOELLER:
Will the roughly 62 fuel cycle 7
facilities and licensees that it is anticipated to cover, 8
will those be enumerated anywhere to make sure that someone 9
else unsuspectingly is not suddenly, you know, put into this 10 group?
11 or the rule will just b'e stated generally, in 12 a generic manner?
S 13 MR. McGUIRE :
The rule will be stated in a generic d
14 manner.
This is just our estimate of how many people would t-15 be affected by the rule.
16 It may be a little higher or a little low, and 17 licensees change their possessions periodically, sometimes 18 going up and sometimes going down.
19 MR. CARBON:
Will it include large reactor 20 isotobe makers, like Valasecos?
21 MR. M cGUIRE :
I don't know the answer to that.
22 Valasecos would have to have a plan because of the reactor.
23 Now whether they -- generally what we would 24 try to do -- I don' t know exactly how that would be treated O
25 in this case.
4 e
c -
7 - Jos Wal 245 1
I don' t know if California is an agreement State.
()
2 It is something I don't know the answer to.
3 of these 60 licenses, they will have the option 4
'to perform an evaluation to show that a large release is not 5
possible due to, perhaps, the way the physical form of the 6
material, oor the way it is stored or handled.
7 And we estimate that about 15 licensees would 8
take that option.
And then the third option is to submit
.9
.an emergency plan.
And we expect about 30 plans to be 10 submitted.
11 We presently hope to go to the Commission on 12
. about July 31st.
13 MR. FOSTER:
This will include low level waste --
~ 14 MR. McGUIRE:
Potentially, it would.
In our 15 analysis we ccarluded that.they would not have the possibility 16 of one rem effective dose equivalent, which is our cutoff 17 criteria.
18 MR. FOSTER:
But they would have to file for 19
. exemption, right?
20 MR. McGUIRE:
Yes.
Now, the NRC currently has 21 no low level waste -- this number does not include agreement 22 state licensees.
23 MR. MOELLER:
Now, if you are -- if this' rule 24 were promulgated and approved, you would immediately arrange o
ss 25 with every agreement state to place -- to incorporate this
~8*
246 1
rule into their state regulation, would you not?
(
2 MR. McGUIRE :
That is correct.
The Office of 3
State Programs has said that they will -- they intend to
.4 make this an item of compatibility, so that the states 5
would be required to amend.their own regulations to adopt 6
an, equivalent, or similar rule.
7 MR. PARKER:
How many facilities then would be 8
affected?
9 MR. McGUIRE:
Well, we are guessing.
We really 10 don't know what they have got out there, but we are guessing 11 that they have got, perhaps, five or ten in addition to 12 what we have here.
So, they have no fuel cycle facilities, e
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13 Five or ten plans.
There may be additional ones N_)
14 '
that would fall under one of these exemptions.
15 MR. PARKER:
Okay.
16 MR. McGUIRE :
We have analyzed the accident 17 scenarios that are possible.
18 (Slide) 19 We find that the most significant accident is 20 sudden rupture of a large, heated UF-6 cylinder, the radiation 21 in this case is not the concern at all.
22 The radiation levels don't even reach the 23 protective action guide values.
It is chemical toxicity 24 which is our concern, and this is really by a rather wide
\\'
M margin.
9.
247 1
We feel that a few injuries due to chemical 7k,)
2 toxicity may be possible out to, roughly, a mile, should s
3 one of these large 14 ton cylinders suddenly rupture.
4 A few fatalities we feel offsite are probably 5
not credible.
We have to put in the word, 'probably,'
6 because the calculations have a certain amount of uncertainly, 7
and perhaps the upper limit of the uncertainty bounds just 8
slightly exceeds what could be fatal.
9 For fires, fires for radiation effects are really 10 our most important accident, and really the only significant 11 one.
That is what we are concerned with.
12 Still, we feel that there is no chance of any
~s
)
13 acute injuries or acute fatalities from any release at any (d
u 14 of these facilities, but the one rem protective action guide 15 dose might be exceeded for as much as a mile for a couple 16 of licensees, and perhaps to a quarter or half of a mile 17 for some others.
18 A third accident that just gets us a little bit 19 over the PAGs for the conservative calculations is a 20 pulsating criticality accident, where it is assumed not to 21 just provide a prompt burst, but continue perculating for a 22 period of eight hours.
i 23 MR. MOELLER:
A couple of comments on that.
In 24
/~%
the second one you mention plutonium.
Now, in the table, b
M at least as I read it in your proposed rule, plutonium is not
10.
248 1
one of the nuclides listed, you know, in hcw much you can O
2 have.
g 3
MR. McGUIRE:
Okay.
The Table is in the Part 30.
4 Plutonium is licensed under Part 70.
5 MR. MOELLER:
That is fine.
6 MR. McGUIRE:
I must admit I don't recall exactly 7
_what we do with plutonium now, but it would be under 8
Part 70.
9 Okay.
And we list it specifically in 70.2 as 10 two curries is the limit.
11 MR. MOELLER:
Okay.
And would uranium be listed 12 there also under 70, because it is not --
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. 13 MR. McGUIRE:
Basically, we don't feel that you
\\~/
14 can get a critical radiation dose from uranium.
15 MR. MOELLER:
Okay.
16 MR. McGUIRE:
So, we don't list it except for the 17 uranium hexifluoride produced, for the criticality.
18 MR. MOELLER:
One of the questions you asked the 19 public for, and obviously us for specific comment, was 20 whether your scenarios -- you know, to comment on them -- and 21 you presented them here.
What about sabotage?
22 MR. McGUIRE:
About the worse we feel that they 23
.could do is a fire.
We have looked at explosions also, and 24 we find that we don't get as large a release with an explosion 7g
(
)
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25 unless we follow it up with fire, j
i 11.
249 1
So, in essence, you believe that in proposing
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2 these scenarios you covered whatever a saboteur might do?
3 MR. McGUIRE:
Yes.
Are you saying that a saboteur 5
couldn't put a hand granade beside two or three UF-6 6
cylinders?
7 MR. McGUIRE:
No.
We are saying that the release 8
of the UF-G cylinder is certainly possible.
A hand granade 9
will rupture it -- well,.might rupture it -- I don't know 10 whether it would or not, but that is an accident.
11 We are prepared for the rupture.
12 MR. CARBON:
In tlie saboteur scenario, could they
/N 13 rupture several of them?
km 14 MR. McGUIRE:
Perhaps.
The basis of emergency 15:
preparedness is that you have enough flexibility in the 16 response that you can respond to accidents that are slightly 17 different than what you envisioned.
18 I think in the case of a satoteur, if a saboteur 19 wants to go out and do some real damage, what we have to do 20 is hope and pray that he attacks one of these facilities, 21 because it is going to be very hard for him to have an effect 22 But on the other hand, if he goes after a school 23 bus full of children, we can have real problems.
24 MR. FOSTER:
Steve, you mentioned that several
%.)
M of the licensees might be exempt or not because of I-131.
12.
250 1
Can you show us a little bit more about why
%,)
2 that particular nuclide -- what are the circumstances?
Are 3
these hospitals, or what?
4 MR. McGUIRE:
Let me come back to that.
That 5
is on a later viewgraph.
6 MR. CARBON:
All right.
7 MR. AXTMANN:
Question.
On Page 90 of, I guess, 8
NCFR 70, paragraph 2.4 starts out with:
The accident with 9
the greatest potential hazard appears to be a release of a 1
10 large quantity of UF-6.
11 MR. McGUIRE:
Yes, sir.
12 MR. AXTMANN:
In such a case, evacuation of
(} ~
13 several kilometers downwind would be appropriate for very
%.)
i 14 calm weather conditions.
The plume is easily detectable l
15 by sight and by smell at levels well below levels likely 16 to cause injury.
17 That is, the people downwind would be able to 18 see the plume coming and would be able to judge for themselves 19 when they had reached an area of safety.
20 This is, I would guess, you are taking the worse 21 possible case here, but I would think a UF-6 cylinder could 22 be ruptured at 1:00 a.m.,
and figuring out a strategy at 23 that time might not be as easily -- what I am saying, that 24 doesn't sound like a very conservative scenario to base a f-s 25 judgment on.
13.
251 1
It need not be midnight.
It could also be heavy
/
s
(,)
2 weather conditions which might help ameliorate it.
I wonder 3
if you have any comment on that.
4 MR. McGUIRE :
Let's look at this question of 5
conservatism, and let me do it over the next couple of 6
slides.
That is one of the subjects that is coming up next.
7 MR. AXTMANN:
Okay.
8 MR. McGUIRE:
Okay.
9 (Slide) 10 MR. McGUIRE:
This is a graph of Pi over Q, 11 or concentration per currie of release rate.
And our 12 quantities are based on basically assuming one meter a second
(~')
13 with no bouyancy, so that gives us a value really -- this
%.J 14 curve here (pointing.)
15 Now, what we have done is we have truncated this 16 and an intercept fraction of ten to the minus 6, which is the 17 value at about 100 meters.
18 The reason for that is that really does require 19 some very unusual assumptions at closer distances.
It would 20 require the assumption that someone standing in that distance 21 would stand in very dense smoke.
22 For instance,.F-1, so essentially it is almost a 23 complete calm.
24 We know it is dense smoke in case of a fire,
,r g t
25 because the release fractions that we have calculated are base <1
14.
252 1
on large amounts of fire, large amounts of heat, and the
,-)
person is assumed to stand there, and the assumption also
(
2 ws 3
is that even though it is calm, and there is a very hot, 4
tense fire, that the plume has no bouyancy, it just kind 5
of comes out.
6 These assumptions, when you start to put them 7
together, really don't make too much sense at very close 8
distances, where the plume is getting very intense.
9 So, we did truncate it at this value.
10 Now, if we consider that the plume is bouyant, 11 that it will reach a 20 meter height, we come up with a 12 curve for F 1 meter a second that looks more like this.
[]
13 (Pointing.)
%_j 14 So, really, in the case of a hot fire, we expect 15 to see a concentration perhaps more like this.
(Pointing. )
16 So, even though we are basing our regulation on 17 this particular value, we realize that we have got a fairly 18 large conservatism here.
(Pointing.)
19 Now, you might wonder if this does apply to the 20 UF-6 case, and we believe that it does, because we have had 21
-- the UF-6 will react with the moisture in the air.
It 22 is a very highly texathermic calculation, and we had some 23 calculations done at Oak Ridge about plume bouyancy, and i
24 they did estimate that we would get a 20 meter plume rise.
25 So, the UF-6 calculations they did really for
253 15.
1 F-1 followed something more like this.
(Pointing.)
. (m,)
2 Now, we are not entirely satisfied with that 3
model, so we are really, in our description -- we are 4
discounting both this and this (Pointing. ) and saying that 5
these probably represent somewhat of a range that we would 6
expect to see.
7 The concentration is somewhere in between.
8 Now, in the case of F-1 as being very adverse 9
meteorology, in the case -- basically, a night time 10 position, in the case of more typical meteorology, the 11 four and a half meters per second, we are down by almost 12 an order of magnitude in our concentrations, and if we
(}'
13 throw in some bouyancy, we are down by close to two orders N-14 of magnitude.
15 So, I will continue on with the discussion of 16 the conservatism in the, calculations with some other factors.
17 Looking at what we are assuming and calculating 18 our values versus -- these are the values that went into 19 the assumptions, the guidance that went into producing the 2
table of nuclides, and looking at some factors that might 21 mitigate those.
~
22 We assume, first, that the entire possession limit 23 is assumed to be involved, and generally most facilities will 24 not store all their material in a single location, at least s
M not the larger ones will.
b
254 16.
1 We are assuming worse case release fractions.
[)
2 Now, the release fractions that we got, highest release v
3 fractions that we obtained were for fires.
4 And they were experiments designed to maximize 5
release fractions, so they were like placing powders on 6
flammable surfaces and putting large amounts of flammable-7 material underneath.
8 In an actual case, we expect to see less.
9 MR. AXTMANN:
Sorry.
Powders?
10 MR. McGUIRE:
Powders.
Most of the materials were 11 powders, yes.
12 MR. MOELLER:
You were trying to simulate the 13 worse conditions.
f-wg O
14 MR. McGUIRE:
The experiments were done so that 15 the materials of concern like Amarecium-1, plutonium, or 16 uranium.
Cobalt -- material is essentially on top of large 17 amounts of flammable material.
18 We give low credit for engineering safeguards or 19 response efforts, so if, for example, there is a sprinkler M
system in the building, we assume it fails.
The sprinkler 21 system, of course, would greatly reduce the release.
22 We assume beyond really 100 meters that people 23 in dense smoke make no effort to move.
That they would basically stand on the plume centerline for the entire duration 24
/
2 of the release.
17.
255 1
The quantities on the table are based on no
/3 2
[g bouyancy assumption.
3 We, in the case were various solubilities of 4
particles are possible, like uranium in the new ICRP models 5
-- very highly soluble -- we picked the dose conversion 6
factor which gives the highest dose.
7 For particle size, we picked one micron, which 8
gives you a highly respirable particle.
8 We assume adverse meteorology.
The F-1 meter 10 a second.
Your average meteorology drops that by a factor 11 of ten.
12 We might mentio'n that this particular one is used 13 by the Department of Transporation in calculating their NJ 14 evacuation distances for a truck or train accident involving 15 hazardous chemicals.
16 They claim that from their experience that the 17 4.5 is a good value to use.
It has worked out in practice 18 and is reasonable -- reasonable distances.
19 This is the surface roughness caused by obstacles; 20 buildings and trees in the way, it is 1.2, and that is 21 negligible.
22 We send no shifts ir. wind direction during the 23 duration of the release.
For criticalities, we assume that 24 they pulsate every ten minutes for eight hours, and doses b
's' 25 are calculated on the plume centerline, and if you start
- - _ _ _ _ _. - ~, _..
256 18.
I filling out 100 or 200 meters, this is the area where the
()
2 dose is really concentrated.
3~
Even if you move it ten feet in one direction, 4
you lower the dose significantly.
5 Okay.
Now, many of these do not apply to UF-6.
6 This doesn't.
(Pointing.)
This doesn't.
(Pointing.)
The 7
bouyancy -- I think the most important one for UF-6 is --
8 oh, actually another one that is not even in here that we 9
do at one o' clock in the morning, our calculations are for 10 doses -- people standing outside, they are not inside the 11 building.
12 I don' t think we are really representing these 13 as the most conservative case possible.
I think we are
("']s 14 representing them as having a great, large probability of 15 being conservative, but I think people with a bit of 16 imagination -- perhaps -- there are many factors, think 17 up a case where we might have a release that was larger.
18 I think the nature, again, of emergency response 19 is that it is flexible enough that when one can respond 20 to an accident 21 MR. PARKER:
I made a quick calculation of those 22 conservation factors, assuming all apply -- 10 to the 9th, 23 and somehow or another that strikes me as a little odd to 24 base a rule on 10 to the 9th conservatism.
~/
25 MR. McGUIRE:
What we have done is in the revised
19.
257 1
version of the regulatory analysis which didn't deceive, it O
2 is rather than just representing the dose, we have taken a L( )
3 range of about a hundred in most of the cases, and we have 4
expressed the dose from a severe accident rather than just 5
saying, perhaps, in some case 5 rem, we say -- we give a 6
range of a hundred and say it is between -- dose of a severe 7
accident, between fifty millarem -- five rem.
8 MR. CARBON:
Steve, have you looked at this from 9
the standpoint of hcw this would compare with requirements 10 of some oth'er industry, a tank of chemically toxic 11 something?
12 You have indicated the worse concern here is
('~
13 the large cylinder of UF-6, and concerned about chemical N-14 toxicity.
So, we have the Nuclear Regulatory Commission, 15 which is always very, very conservative, and it comes along 16 and sets something up.
Perhaps it should, maybe the law 17 says-it should, but is what you are setting up here -- do 18 you have any idea, does it compare at all with what is done 19 elsewhere in industry?
20 MR. McGUIRE:
Basically, we compare it with what 21 DOT recommends for accidents, or concentrations of a factor 22 of ten.
23 MR. CARBON:
That is for Transporation.
24 MR. McGUIRE:
That is for Transportation, yes.
E
-s V
25 MR. CARBON:
How about Dupont Chemical Company
20.
258 1
sitting some place.
/O
(,)
2 Does it have to have plans like this for tanks 3
of chemicals sitting around?
4 MR. ROHRER:
May I?
5 MR. MOELLER:
Give us your name.
6 MR. ROHRER:
I am David Rohrer, I am with the 7
Office of Inspection and Enforcement, Emergency Preparedness 8
Branch.
For the Dow Midland complex, which is across the 9
river from the --
10 MR. CARBON:
Former Midland Plant, il MR. ROHRER:
There are approximately 200 process 12 lines, that are two miles long and about half a mile wide.
(~T 13 There is an individual emergency response plan for each
'x_Y 14 individual process line.
15 There is an emergency response plan for each 16 individual building, and there is an overall corporate 17 emergency response plan for that facility.
18 There are over three hundred emergency response 19 plans for that single complex.
That doesn' t include the M
Dow Corning complex that sits to the east of that.
21 MR. CARBON:
Is this typical throughout industry?
22 Is this an EPA requirement?
23 MR. ROHRER:
It is my experience that for a
24 facility like Dow, or Union Carbide, or the larger manu-
-s
\\-
25 facturers, their concern is worker occupational health and
I 21 259 1
safety.
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)
2 Their safety records are such that the biggest s
3 concerns they have now are not worker accidents at the 4
site, it is worker accidents at their own homes; mowing the 5
lawn, painting the walls.
6 That does not necessarily apply to smaller 7
industries.
And I guess what you are saying 9
is that those are Company --
10 MR. ROHRER:
Company-sponsored programs.
11 MR. CARBON:
Not Federal?
12 MR. ROHRER:
That is correct.
('~}
13 MR. CARBON:
Are there any Federal requirements?
'N_J' 14 MR. ROHRER:
To my knowledge, the only things 15 would be the OSHA requirements, and they would not assume 16 a role in emergency planning of that nature that I am aware 17 of.
So then this is, I guess, unique 19 as far as Federal requirements?
M MR. ROHRER:
To the best of my knowledge.
21 MR. MOELLER:
Since you mentioned this subject, 22 are you aware of the extent to which nuclear power plant 23 utility operators practice good occupational safety and 24 health within their plants; within their nuclear power
-s
(
25 plants?
22.
260 1
MR. ROHRER:
I am an emergency preparedness
[
}
2 reviewer and inspector, so I don't get into the occupational x./
3 health and safety, Part 20 it would be.
4 MR. MOELLER:
Okay, thanks.
5 MR. PARKER:
What would be your impression based 6
upon your visits to the plants?
7 MR. ROHRER:
My impressions would be overall 8
favorable.
I have seen a number of areas where prudence 9
can be taken.
10 I believe that -- shall we call it enlightenment 11 by involvement with emergency planning has led to increased 12
-worker safety in other areas, occupational safety.
The 13
'%g crux of the whole situation is management attitude.
~>
14 MR. McGUIRE:
This is a table of quantities.
15 (slide,)
16 Byproduct materials, where one would have to consider in an 17 interim plan.
18 I put on this asterisk number, it shows the 19 largest possession limit allowed.
These are all precisely 20 correct, because they go up and down as time goes on.
21 But we see that there are really just a few 22 isotobes that are important.
We have Titanium, where we 23 have perhaps five times.
24 Now, Iodine 131 is interesting.
That 500 is the
/O s/
25 maximum possession limit of any licensee.
In a nuclear power
l 261 23.
1 plant, the inventory of radio iodine is approximately five
/
i !
2 hundred million curries.
v 3
So, notice that the source term is a factor of 4
ten to the sixth.
5 That is overwhelming, ten to the sixth.
6 MR. FOSTER:
These are quantities which are 7
included in licenses, or quantities of concern?
8 MR. McGUIRE:
These are quantities -- the 9
types of quantities that would require a plan, okay?
10 MR. FOSTER:
So these must be related to dose 11 in case of an accident?
12 MR. McGUIRE:
These are the quantities calculated 13 to deliver a one rem effective dose equivalent,
{}
v 14 MR. FOSTER:
Now, what kind of a scenario did 15 you use for delivering this dose?
Is this strictly an 16 external dose plus inhalation, or did you use something 17 besides that?
18 MR. McGUIRE :
We used external, plus inhalation, 19 plus ground shine.
20 MR. MOELLER:
The numbers up here without an 21 asterisk, how do we know what the licensee can have compared 22 l
to what here is threshold?
23 I mean these are the numbers -- take Copper 64, 24 200,000.
That is how much copper would give an effective
-s M
does equivalent of one rem.
But how much copper can a typical
262 24.
1 licensee have?
(O) 2 MR. McGUIRE :
I can say that out of nine thousand 3
licenses, no one has been in excess of 200,000.
4 MR. MOELLER:
So, you asterisk only the ones 5
where people can have more than the --
6 MR. McGUIRE:
Theoretically, they could apply 7
for any amount.
8 MR. MOELLER:
Sure.
9 MR. McGUIRE:
I asterisk the ones where the 10 current license is in effect at this moment.
Would allow 11 greater than --
12 MR. MOELLER:
Okay.
(~S 13 MR. PARKER:
I would like to ask another t
)
v 14 question along the same line.
Iodine 131 apparently is 15 the one which has the largest multiple -- greater -- a 16 factor of a hundred of the permissible release.
17 MR. McGUIRE:
Okay, it is actually --Americium --
18 MR. PARKER:
Okay.
Did you take into account 19 played out for example, in iodine releases in your calculations?
20 MR. McGUIRE:
Yes.
We assigned a release function 21 for iodine of.5; in other words 50 percent is to go out, 22 where does the other fifty percent go?
%)
We attribute that to a large number of possible 24 factors which we really cannot quantify, but played out f
25 is one of the things.
Involatile products would be another.
25.
263 1
Since iodine is decayed rather quickly, the inventory at r-(%)
2 any one time is likely to below the five hundred.
That 3
would be five hundred after a shipment is received.
4 So, we do reduce the iodine by a factor of two 5
to account for factors like that.
6 MR. FOSTER:
Intuititively I am amazed at 7
some of these.
For example Cobalt-60 you have 5,000 versus 8
five -- a factor of a thousand different.
Can you tell me 9
what the reason for that difference would be?
Is this associated with Cobalt 60 as not having hardly any release to 4
11 as far as the source term is concerned?
12 MR. McGUIRE :
Cobalt-60, I would have to look 13 and see what release fraction we used, but it was much less
)
14 than Iodine.
Iodine is 50 percent release.
15 I think Cobalt is -- I don't recall.
It is 16 either one percent or a tenth of a percent.
We end up with 17 a factor of at least fifty right there.
18 MR. FOSTER:
You are still a long way from a 19 thousand.
M MR. McGUIRE:
Yeah.
What is it, Ron?
21 MR. CORAVELLI:
I was just going to interject 22
.001 was the release rate.
23 MR. McGUIRE:
So we are assuming -- so there is 24 a factor of 500 there.
V 25 MR. MOELLER:
Assume that the population exposed
26.
264 1
had potassium iodine pills available.
(',)N Now, you carefully pointed out in the text and 2
3 orally this morning that the doses you considered were the 4
effective dose equivalents.
Well, that is true except for 5
6 MR. McGUIRE:
That is right.
That is an 7
exception.
It is a thyroid dose volume.
8 MR. MOELLER:
And I understand the box you are 9
in, and I really don't know how to get around it.
I mean, I
10 the FRC said five to 25 for Iodine, and 1 to 5 whole body, 11 so you took the minimum in both cases.
12 But 5 thyroid is not equivalent to one whole 13 body.
(q) 14 It would be about -- well, it depends.
170 to 15 the thyroid is equal to five whole body, so it is five 16 one hundred -- you know, five into 170, it is 34 rems to 17 the thyroid is equivalent to one rem whole body.
18 MR. McGUIRE:
The thyroid number, because of the 19 way that EPA has written their protectivo action guide, is 20 a little more restrictive than the others.
21 MR. FOSTER:
But for the iodine -- the five 22 curries is associated dominently with the thyroid uptake 23 contrasted with --
24 MR. McGUIRE:
Yes.
The dose due to iodine, it
\\_s 25
-- the inhalation dose dominates.
External dose is negligible.
265 27*
1 In fact, the inhalation dose dominates for almost
(
)
2 all the isotobes on this list.
Something like -- Krypton-85, 3
of course, it doesn't.
4 It is dominating -- contributing at least 80 or 5
90 percent of the effective dosage, with just a few exceptions.
6 Inhalation is dominant.
7 The interesting thing about this is the ones that 8
exceed it by quite a bit are really the iodines and a few g
alpha emitters, Bilonium-210, Americium, Curium, and 10 Plutonium, which is not on this particular list, but if we 11 put it, it would also have two curries.
12 We would have a large number here.
Tritium is r" x 13 a factor of five, it is not very much.
Stronium, a factor k,
14 of five.
1 15 Now, the question is what would we require to 16 be in a licensee's emergency plan?
17 (Slide.)
18 A brief description of the facility and site area.
19 An identification of each type of accident for which 20 protective actions for the public may be needed.
21 An analysis of the potential doses to the public 22 from each type of accident.
23 This is just kind of an orientation at the 24 beginning.
It is really a question of what are we preparing n>
25 for.
28.
266 1
Identification of the means of detecting each
\\
2 type of accident, so Chat it would most likely be for a fire
. %)
3 a fire alarm; or for UF-6 release, it would be visual 4
observation.
5 A brief description of the means and equipment 6
for mitigating the consequences of each type of accident.
7 So, we have fire fighting equipment, for example, 8
for the fire.
Perhaps a sprinkler system. Eor UF-6 releares, g
would want to use carbon dioxide, perhaps, to solidify the to material at the leak, to plug up.
One of those is to either 11 cool the cylinder, or knock down the material in the air.
12 A brief description of the methods and equhpment 7-13 to assess releases of radioactive materials.
'G 14 Realistically, these accidents are happening 15 fast.
We are not getting real time concentrations or doses.
16 We are assuming in this case that there just simply will not 17 be time to go out and take measurements of airborne 18 concentrations.
19 As a consequence, you will not be able to project 20 source term for doses, particularly inhaled directly.
You 21 would have to figure out -- first you will have to figure 22 out whether there was a release at all.
23 And this in most of the isotobes that are 24 concerned, would be done with measurement of ground contami-O
'd 25 nation.
29.
267 L
1 It would probably take you months, if not years, f)
\\,%,e 2
to determine the quantity of material that was released.
3 MR. FOSTER:
Are you going to provide specific 4
guidance to the licensee on how to make his analysis of 5
potential doses?
Whether he has to have an emergency plan 6
or not is going to depend upon the dose which he calculates, 7
and from the previous slide you showed us that depending upon 8
what kind of assumptions, from meteorology and other things, 9
you can get a variation that, according to Dr. Parker, 10 perhaps ten to the ninth difference.
11 Now, what kind of guidance are you going to give 12 the licensee here, what numbers he realistically ought to r~
13 use in making that calculation?
.((
14 MR. McGUIRE:
What guidance?
It is going to be 15 very difficult to get Staff consensus in that area.
It 16 would be certainly very nice.
I think in practicality he 17 is going to have no realistic choice but to go back to this 18 curve (Pointing.) in use -- the F-1 with no bouyancy.that j
l l
19 use pretty much this conservative assumptions.
20 He may be able to justify a different release 21 fraction, or a different solubility because of the material 22 that he has that would adjust his dose up or down.
23 MR. FOSTER:
What you are saying is that you are 24 going to expect him to come in with an analysis here which f-sg
'V M-uses the worst assumptions in every case.
7.-
30.
268 1
MR. McGUIRE:
I think that -- well, let's go
)
2 back.
Where he might be able to modify that.
3 (Slide.)
4 I think he could probably take some credit for 5
this -- in fact, I am fairly sure that he could; a 6
particular licensee might be able to show that certain 7-of the material not in process is stored in such a matter 8
that it is not subject to release, or that it is located 9
at different buildings.
10 I can think of the National Institute of Health 11 here in Bethesda has over a thousand different laboratories 12 where they are authorized to store radioactive material.
(}
13 In that case, I think they could make a fairly
\\_/
14 good case that the fire is not going to burn down all 15 thousand laboratories at once.
16 I think they could take some credit for this.
17 MR. CARBON:
Is it spelled out in the regulation 18 that they can take credit for that sort of thing?.
Is it 19 clear that they can?
20 MR. McGUIRE:
Yes.
Ugh --
21 MR. CARBON:
That is enough.
22 MR. McGUIRE:
I suspect it will be hard for them 23 to justify a different release fraction than is used there.
24 I suspect it would be very difficult to take credit for
~s 25 engineering safeguards, because -- like a sprinkler system 1
I
31.
269 1
is the obvious one for fire, but they don' t work all the A
2 time.
3 So, it would be difficult to make that argument.
4 MR. FOSTER:
Would a fire proof safe?
5 MR. McGUIRE:
I think, yes.
I think if you 6
had 2 proof safe, I think what you could do is exclude 7
the quantity that you would have in the safe.
You could 8
use what you would process at one time.
9 So that would be under this right here (Pointing.)
to That you certainly could take credit for.
11 This one, I don't think people -- people in 12 intense smoke making no effort to move, I don't think you 13 can get anything for that.
I think the only -- you may be 14 able to show if you had a fairly large site -- our basis 15 is 100 meters.
16 If you had a large site, you may be able to show 17 the doses at the site boundary would be less than the one 18 rem.
I 19 I really don't think you are going to be able to 20 get any credible bouyancy.
While we presented two curves, 21 I ' don't think we are satisfied that we can predict what the 22 bouyancy would be, so I don't think it would be reasonable 23 to consider that factor.
24 The solubility, you could.
You would know the 25 material that you are working with, and you would know what
270 32 1
the combusted products would be in a fire, and I think you 1(
)
2 could actually assign a correct solubility.
3 You might get a factor of two or three in some 4
cases.
5 MR. PARKER:
If a fire is the problem, why 6
shouldn't you take some advantage of the bouyancy, and the 7
rise?
8 MR. McGUIRE:
Because we don't have -- the NRC 9
does not have a model to include bouyancy that is accepted 10 by the Staff.
11 MR. PARKER:
Just because you don't have a model, 12 you denying physically that it occurs.
(~'
13 MR. McGUIRE:
(Pause.)
Yes.
In this case, b
14.
the possible, you know, uncertainty range, we take the most 15 conservative value.
16 -
MR. MOELLER:
Could a licensee develop a model?
17 MR. PARKER:
The most conservative value is zero 18 rise?
It seems to me. that there is some value the Staff could 19 agree upon.
There are lots of models on plume rise. Things 20 like Tanner's model, and --
21 MR. McGUIRE:
We have considered those, and our 22 meteorologist pointed out that those were rises from chimneys, 23 and that they didn't, necessarily, apply to fires.
24 MR. PARKER:
Plenty of evidence on rises from
/*
25 fires.
33, 271 1
MR. McGUIRE:
And they didn' t fc 31 that there
(~N) 2 was sufficient evidence to accept the different models.
3 3
MR. PARKER:
Any model is what you are saying.
4 MR. McGUIRE:
Any model, right.
5 MR. PARKER:
This would have to go down with 6
defining Pi as three and one-seventh.
7 MR. McGUIRE:
Now, particle size, I don't really 8
know that you can do much with that.
Small factor anyway.
9 For adverse meteorology, we do recommend in the 10 back of the regulatory analysis, basically protective action 11 recommendation, and the response distance to take into 12 consideration the meteorology at the time of the accident.
13 So, that when somebody called the local officials 14
, and told them we recommend prote ctive action such as 15 evacuation, they could then :say out to a distance of 16 such-and-such.
17 That would reflect, I am sure, meteorology at 18 the time.
19 MR. PARKER:
Are you recommending evacuation for 20 one rem dose?
21 MR. McGUIRE:
-- ugh --
22 MR. PARKER:
Is that what you are telling us?
23 MR. McGUIRE:
Yes.
24 MR. PARKER:
IIave you looked at the actual NRC 25 document that deals with the problems in evacuation, the
,.-i, r-,
34.
272 1
. number of people that will be injured and killed in an p) 2
(
evacuation, have you compared that with the test of the 3
1 rem dose?
4 MR. McGUIRE:
EPA has the responsibility to 5
determine at what doses one should consider protective 6
actions.
7 They picked this one.to five rem range.
8 They, in determining that, should have considered 9
these factors.
And we assume that they have done so, and to have done so properly.
11 We'go to the lower end of their range.
12 MR. PARKER:
There is a document -- that blue 13 bound one -- on evacuation, that deals with all the problems
\\
l 14 in evacuation.
15 I find it very hard to believe that one rem dose 16 would cause more problems than the problems of evacuation, I
17 leading to more deaths than the evacuation, particularly 18 in the middle of the night.
19 MR. McGUIRE:
Well, I am not saying that --
20 we are saying that the local officials should consider 21 protective actions.
Really, they do have other options.
22 In the middle of the night it may be more practical to 23 provide -- to give sheltering, for example.
There may be 24 something else more practical, n/
25 MR. MOELLER:
In terms of that comment by Dr.
273 35.
1 Parker, you are using ICRB 26, Publication 26, in applying
)
2 the concept of the effective dose equivalent, but in ICRB 3
Publication 40, their recommendation is that at one-half of 4
a rem projected dose, you consider sheltering, and that at 5
five rem, sheltering is mandatory.
You know, you absolutely 6
should do it.
7 And they also say at five rem you should start 8
thinking about the evacuation and, perhaps, some number much 9
higher, you -- it woul be almost mandatory.
10 You are loc}sd in, then, once again to EPA here 11 when you use ICRP 26, but you can't use ICRP 40?
12 1iR. McGUIRE:
Well, no; We could certainly --
,rm, 13 EPA recommendation in the one to five rem range is that there
)
V 14 be consideration oh protective actions.
15 We are really locked into that range.
I think 16 what you describe from ICRP 40 is quite consistent with 17 that.
18 I would say if you read EPA's document carefully, 19 they are saying -- I would say that sheltering at one rem 20 is quite a reasonable approach, and that that -- if you read 21 it, I think one would feel that that is what they were 22 tending toward.
23 MR. MOELLER:
Well, isn't your proposed rule, 24 though, -- doesn' t your proposed rule state that at one rem g
1 25 you would evacuate?
i 36.
274 1
MR. McGUIRE:
No, it does not.
It does not O
2 state that.
It says -- it merely states that you must y_j 3
make a recommendation on protective action to the local 4
authorities.
5 MR. MOELLER:
Oh, okay.
6 MR. PARKER:
That includes evacuation as a 7
possibility.
8 MR. McGUIRE:
Evacuation is a possibility.
9 Sheltering is a possibility.in your recommendations.
10 Now, the local authorities would be free to take your 11 recommendation or modify it, or do nothing at all.
12 MR. PARKER:
Wait a minute.
Do you really
{)N believe that if you recommended to the Governor of 13 w
14 Pennsylvania that he should evacuate, that he would say:
15 No way?
16 MR. McGUIRE:
First of all, the Governor is 17 not in the loop.
It is the local fire and police.
18 MR. PARKER:
Do you think they would try to 19 second guess you?
20 MR. McGUIRE:
No.
21 MR. FOSTER:
In your material that we had for 22 review, there is a piece there called a regulatory analysis 23 on emergency preparedness.
Page 12 of that, under heading 24 2.1.5, a discussion of conservatism in calculations.
n v
25 The first paragraph says:
Commission's policy is
i 37, 275 1
that emergency planning should be based on realistic O
!,/
2 assumptions regarding severe accidents.
3 References are NUREG 0885.
How does what you 4
are telling us here square with that Commission's policy?
5 MR. McGUIRE:
I guess we will find out in about 6
a month from now when the Commission reviews it.
I don't 7
know.
It is possibly more conservative than they intended.
8 I don't really know.
It is consistent with many 9
Staff analyses as far as methods go.
10 MR. CORAVELLI:
Somehing that has been going 11 through my mind when you were discussing bouyancy, 12 that in fact with contingency planning which by now, 30 13 radiological contingency plans, we were not that rigid.
If
/~}
V 14 a licensee submitted to us some justification as to why they 15 believe the dose shouldn't be that high, or should be reduced, 16 we always did look at it.
If we felt that it was valid, we 17 would give them that credit.
18 So, I don't believe that it is that rigid, and I 19 do believe we would look at it.
3)
MR. McGUIRE :
This is Ron Coravelli who reviews 21 the plans, and he certainly has first hand knowledge of that, 22 so he should be the expert in that area.
23 MR. McGUIRE:
I will give you protective action 24 recommendation that does concern bouyancy.
Call the local O
25 fire and police departments and say:
Help.
38.
276 1
Move people out of dense smoke.
That takes care (O) 2 of the plume meander, plume bouyancy.
In fact, I will do 3
that anyway.
4 We were going through the 12 elements of an 5
emergency plan. At least the second half dozen.
6 (Slide. )
7 The plan should give a brief description of the 8
responsibilities of the licensee personnel should an accident 9
occur, including identification of the personnel responsible 10 for identifying offsite authorities.
11 Should give -- tell the means of promptly 12 notifying offsite authorities, and request offsite assistance 13 resources.
14 A brief description of the members for assuring 15 that recommended protected actions and distances are un-16 ambigiously communicated to response organizations.
17 A brief description of any special instructions 18 licensee would give to police, fire, medical and other 19 personnel.
20 A brief description of the means of restoring 21 the facility to a safe condition af ter an accident, and 22 provisions for conducting onsite drills at intervals not 23 to exceed two years.
24 The plan oefore it was s ubmitted to the NRC would f3 h~
M be submitted to the offiste response organizations.
The
39.
277 1
Licensee then, from their comments, could choc,se to modify
(
)
2 it or not, but in any case would send the comments of those 3
organizations to the NRC with the plan.
4 Now, you saw what was in the rule; let's see what 5
is not in the rule.
6 There are certain things that -- because people 7
associate when they think of emergency preparedness, they 8
think of reactor emergency preparedness.
Our doses and 9
source terms are so much larger -- it should be sort of 10 smaller -- for these facilities, that there are a lot of 11 things that we omit.
12 There are no written' state and local government
/]
13 plans.
'%.)
14 No state and local government approval of 15 licensee plans.
They don't have to approve them.
They 16 send their comments to us.
They may either concur, or they 17 may disagree violently with them.
It is up to the NRC 18 to make the finding of whether the plan is adequate.
19 No public information programs.
20 No emergency classification system, although this 21 particular item is still -- there is still some controversy 22 in the Staff of whether this will actually continue, or 23 added in as an additional element.
24 No emergency action levels.
This is a concept O]
\\
M of certain indicators in the control room which indicate a
40.
278 1
certain condition in the plant.
For the simplified cases
()
2 that we have, it is considered an inappropriate item.
3 No specific emergency planning zones for plume 4
exposure or ingestion.
We do have a recommended response 5
distance.
We have identified emergency response organizations,
6 but no EPZs.
7 No real-time dose projections.
The timing of 8
these actions, the timing of these things, we don't consider 9
that feasible.
10 MR. MOELLER:
You say no FEMA involvement, and 11 yet Item 12 was provisions for conducting onsite drills at 12 intervals not to exceed two years.
/~ \\
13 How do you -- since FEMA must observe and judge
()
14 all nuclear power plant emergency drills, how do you exempt 15 yourself here?
16 bm. McGUIRE:
In this case, we would envision 17 the drill involving only onsite people observed by the NRC.
18 MR. MOELLER:
Okay.
So, it is exclusively onsite.
19 There will be no education of the people offsite?
I thought 20 there would be.
Pamphlets or something.
21 MR. McGUIRE:
Public education?
22 MR. MOELLER:
- Yes, 23 MR. McGUIRE:
To the public, no.
No public f
l 24 information programs.
rs l
V 25 MR. PARKER:
What about fire and police, medical, i
l
41.
279 1
and other emergency personnel?
(,)
2 MR. McGUIRE:
Okay.
The response organizations s
3 would be given a copy of the plan before it was submitted 4
to the NRC, so they would have a chance to see this and 5
review it and comment on it.
So they would be aware of it.
6 The other firemen, it would involve them in 7
instructions.
Some of the instructions may be given to those 8
personnel prior to the events happening.
9 There may be certain instructions that the 10 licensee would recommend for fire and police.
11 MR. MOELLER:
But your thinking is then if you 12 train the police and the offsite response people, and you f
13 train the onsite people, then if it happens the public will 14
-- there would be enough people around to guide the public 15 to handle it?
16 MR. McGUIRE:
True.
This is what happens in 17 transporation accidents.
A truck overturns at some point.
18 The police establish evacuation distances without any public 19 information programs.
20 MR. FOSTER:
I think Dave mentioned here training 21 of police and fire.
Am I overlooking -- I guess it is in 22 Item 10 here, a brief description and special instructions 23 licensee would give to fire, police, medical and other.
7-Is that the same as training?
Othe rwise, I don't 24 k '/
M see where the training of police requires --
i
,. - - - - = -.
m i
42.
280 1
MR. McGUIRE:
Training is not required.
g 2
Instructions is one of the things that could be included, but-g,j 3
it is not required, training of the people.
4 It may be -- the other options that you would 5
have would be a letter, a sheet of paper, saying this is 6
what we recommend, for firemen, for example, entering our 7
site.
8 MR. FOSTER:
See if I am interpreting your 9
emergency plan and what it includes here, then, from a 10 realistic point of view, that it requires that the plant 11 have some system for identifying that an accident has 12 occurred, the workers on site should know what to do
(~'g 13 themselves on site in case of an accident and telephone police V
14 MR. McGUIRE:
Yes.
15 MR. FOSTER:
And they should telephone the police.
16
. In terms of coping with an accident, it seems to me that is 17 what is in the plan.
18 otherwise,.why it is -- you know, it is describing 19 what might happen and all this sort of thing.
20 As far as action in case of an accident, it seems 21 to me that is the sequence.
22 MR. McGUIRE:
Well, we have Number 6 there -- well, 23 Number 5, means of mitigating the accident as well.
I guess 24 you would say that is the licensee.
\\-
25 MR. FOSTER:
That is the licensee, yeah.
43.
281 1
MR. MOELLER:
Well, Number 9 though says that
(^T
\\m,/
2-you have a brief description of the methods for assuring 3
that recommended protective actions and distances are 4
unambiguously communicated to response organizations.
5 Is that done during the accident, or ahead of 6
time, or what?
7 MR. McGUIRE:
This is done during the accident.
8 MR. MOELLER:
And yet somewhere else, it says 9
you had a half hour.
I remember reading that in the report.
10 MR. McGUIRE:
Really, the fire department is 11 probably going to, in most cases, end the release within half 12 an hour.
(}
13 What we are saying here you don't have half an V
14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.
You really have a matter of minutes.
Anything beyond 15 half an hour is not likely to be very -- have much effect.
16 MR. MOELLER:
Right.
17 MR. PARKER:
It appears to me that most of the 18 people you are talking about, also have a number of chemicals, 19 non-radioactive materials on their site.
20 How does this plan compare with the National 21 Contingency Plan.
You are asking them to duplicate exactly 22 what they have to do in the National Contingency Plan.
23 MR. McGUIRE:
I am not familiar with the National 24 Contingency Plan.
I really can't discuss that.
7g 25 MR. MOELLER:
Does the National Contingency Plan,
44.
282 1
Frank, require emergency planning?
(
)
2 MR. PARKER:
And training?
v 3
MR. ROIIRER:
On part of the licensee?
4 MR. PARKER:
No, local officials.
5 MR. ROHRER:
The National Contingency Plan is 6
a provision by which the Federal Government responds.
7 MR. PARKER:
But the local officials are trained 8
at the same time.
9 MR. ROHRER:
Through FEMA.
10 MR. PARKER:
I think it would certainly be 11 worthwhile to see how it compares, and whether or not you 12 are duplicating those people.
(""N, 13 MR. McGUIRE:
I think it would be very -- a good
',v >
14 way to do it if the facility has basically one emergency 15 plan for coping with a whole series of different types of 16 things, where radiation was just one of the items.
(
17 If we compare radiation to some of the toxic 1
18 chemicals that are used in industry, you can see that it i
l 19 is really very minor.
20 MR. PARKER:
I agree.
21 MR. FOSTER:
Relative to Number 9 here where a l
22 brief description of the methods for assuring that recommendc d 23 protective action is communicated, who makes that 24 recommendation?
Is it somebody at the plant?
(
)
25 MR. McGUIRE:
Yes.
45.
283 1
MR. FOSTER:
Now --
f~
-( )
j 2
MR. McGUIRE:
If you are looking as to who it 3
is likely to be, the accident -- well the F-1 meteorology 4
is a night time weather condition.
5 Most likely it is going to be the night watchman.
6 Most likely he will be the only person on site during this 7
case, so he is going to do it.
4 8
MR. FOSTER:
So, the night watchman is going to 9
be the guy that probably calls up the fire department and 10 recommends that some protective action for people?
11 MR. McGUIRE:
Yes.
That is why it has to be 12 written out in advance.
Probably a brief sentence or two
("')
. 13 that he can read.
N/
14 He wouldn' t have time for anything more than J
15 that.
16 MR. MOELLER:
Back to what Frank Parker was 17 saying, as I recall most major cities where they have radio 18 nuclide users, have existing plahs where they work with the 19 fire department.
N I know in Boston the fire department knows which 21 buildings radioactive material are in, and which ones they 22 would have to be careful about entering in case of a fire 23 and so forth.
24 liow, then, does this possibly duplicate what is O
25 already being done there?
- 46..
284 1
MR..McGUIRE:
Ugh --
m
)
2 MR. MOELLER:
In fact, I have seen little brochures,
j 3
you know, on what a fireman needs to know about radioactive 4
materials.
1 5
MR. McGUIRE:
Fine.
Thqrjust -- here, attach a 6
copy of the brochure, and say the instructions.that we give 7
are attached.
8 MR. AXTMANN:
I have a problem with what would 9
be in the Licensee's emergency plan.
No. 10, a brief 10 description of any special instructions the licensee would 11 give to fire, police, medical and other emergency personnel.
i-12 This would be something in somebody's file.
What n
13 would not be required would be written state and local 14 government plan.
15 Taking those two together means that you don't 16 want to inform the local government, or do you?
17 MR. McGUIRE:
You do inform the local government.
18 MR. AXTMANN:
Why wouldn't they want to have a 19 written local plan?
Given that.
20 MR. McGUIRE:
They just don't do it for the 21 magnitude of the accident.
Think of a fire in this building.
l The firemen have general procedures.
They don't have a 22 23 specific written --
24 MR. AXTMANN:
But they don't have --
25 MR. McGUIRE:
-- specific for this particular l
47, 285 1
building.
. f3
(
)
2 MR. AXTMANN:
But they don't have cylinders of 3
UF-6.
4 MR. McGUIRE:
A cylinder of UF-6 wouldn' t be as 5
dangerous as a fire in this building.
People are likely to 6
die if this building burns.
7 They are not likely to die if a UF-6 cylinder 8
ruptures.
9 I am not saying that we prohibit them.
It is 10 just that we don't require those -- that the state and local 11 governments write a plan as a condition of issuing a license 12 to that facility.
13
)
The local fire and police departments, in their 14 judgment, decide that it is appropriate to write a plan, 15 they certainly may do so.
16 We are saying that the NRC will not shut down that
[
17 facility if they fail to do so.
I 18 MR. PARKER:
The thrust of a lot of the questions 19 is is this necessary, and since the President issued an 20 Executive Order saying that all sorts of regulations of this 21 type have to go to OB for just that purpose, and in your own 22 document you say that it is not very cost effective, do you 23 really believe that O&B would authorize this?
24 MR. McGUIRE:
(Pause.)
I don't know what their
,s 25 responsibilities are.
You are asking hard questions.
l l
m
48, 286 1
MR. MOELLER:
Go ahead with your slides.
[)
2 MR. McGUIRE:
They are just about done.
Just A-3 the last one.
4 Just looking at where -- what licensees are.
5 For UF-6, we have a total of 11; two of dhem have the large
-6 14 ton cylinders at the production plants.
7 Nine of them have up to two and a half ton 8
cylinders.
This is.the. enriched uranium.
9 Fires involving byproduct materials, there are 10 seven licensees that would be affected.
Ten that would have 11 over two curries of plutonium.
12 They are criticality, but not having a plan 13 for UF-6, there would be three licensees.
(
14 A total of 31.
These are, essentially, identical
- 15 to the ones that NMSS issued orders to several years ago.
16 MR. MOELLER:
Okay.
In the way of going through 17 the reports and offering some comments, why don' t we have 18 the lights on.
19 You are through with all slides.
M MR. McGUIRE:
Yes.
21 MR. MOELLER:
You have asked for comments on the 22 scenarios, and you have asked for comments on the conserva-M tisms in the analyses, and I think we have already covered 24 that.
25 The NRC Staff was doing up a fuel cycle facility l
~-
L
49.
287 1
accident analysis handbook.
(D
_j 2
Where does that stand?
3 MR. McGUIRE:
That is still proceeding.
That 4
particular information though really -- well, it analyzes 5
fires and explosions in the plant to determine, for example, 6
whether filter systems would actually hold up under fire 7
conditions.
8 Now, our assumption is that the filter systems 9
fail.
10 MR. MOELLER:
But I would think this handbook 11 would be very useful to anyone involved or coming under this' 12 proposed rule.
("')
13 You say it is coming along, but we heard that
%/
14 on November 23rd last year.
Do you know what sort of 15 priority it has?
16 MR. McGUIRE :
That is currently being funded and 17 managed by NMSS. I don't know.
18 MR. MOELLER:
All right.
We can ask them.
19 Okay.
What is the status of the revision of NUREG 07627 You 20 mention here on Page 9 that --
21 MR. McGUIRE:
We have not started anything unless 22 NMSS has some ideas.
23 MR. MOELLER:
Well, see, it is a standard format 24 and content for radiological contingency plans for fuel cycle n'
x' 25 and materials licensees.
50.
288 1
MR. McGUIRE:
Yes.
()
2 MR. MOELLER:
I sort of thought it was right 3
intimately mixed up with what we are doing here.
4 MR. McGUIRE:
It is.
It really would describe 5-in more detail what we mean by these items, but we don't 6
envision putting that -- reissuing that until the final 7
comes out.
We have not started work on that at this time.
8 MR. MOELLER:
Okay.
Next, on Page 16, you give 9
these numbers, ten to the minus 4 to ten to the minus 5th 10 per year.
11 I am working with the proposed rule.
You give 12 those numbers.
("]
13 You say the probability of a major release is
\\m) 14 less than 10 to the minus 4, and the probability of a major 15 release simultaneously with highly adverse meteorology is 16 less than 10 to tha minus 5, so that immediately tells me 17 that adverse metecrology occurs ten percent of the time.
18 I presume that is correct.
I have no reason to 1
19 question it.
20 MR. McGUIRE:
Well, the F-1 is considered a 21 ninety-five percent --
22 MR. MOELLER:
Oh, okay.
So that is reasonable.
23 Where does the 10 to the minus 4 come from?
24 MR. McGUIRE:
That comes from the probability O
25 of a fire in a sprinkler facility.
This is available from
289 51.
1 insurance statistics.
p
-V 2
MR. MOELLER:
And you did say because there were 3
such a large number of the facilities that you have under 4
consideration, you do have some statistics.
5 MR. McGUIRE:
Those statistics are just for 6
industrial buildings.that the insurance companies insure.
7 That is the numbers that they would use for setting rates 8
on a reasonably fire proof industrial structure with a 9
sprinkler system.
10 MR. MOELLER:
Okay.
On Page 12, you exempted the 11 spent fuel, and you mentioned this earlier.
12 How do we. exempt the spent fuel facilities?
h 13 MR. McGUIRE:
Well --
U 14 MR. MOELLER:
I can't find it at the moment.
15 MR. McGUIRE:
Spent fuel is under Part 72.
We 16 in a sense exempt them by not including an amendment in 17 Part 72 to require this type of planning.
18 Part 72 does have an -- emergency requirements 19 in it.
Those are in the process of being changed.
They 20 now kind of cross reference the Part 50 reactor requirements, 21 and that will be amended to delete that, and focus the 22 emergency preparedness onsite.
23 MR. MOELLER:
Well, I hear you, but I am not 24 gettin3 an answer, at least as I see it.
25 Where would spent fuel be stored that should be i
L
290 52.
1 considered?
At Morris, Illinois, is that what we are talking
_(]
2 about?
%J 3
If it says Morris, Illinois.
4 MR. McGUIRE :
Yes.
5 MR. MOELLER:
Now, why do -- with millions of 6
curries, why is that exempted?
Is it because it is covered 7
in another part of the rule?
8 MR. McGUIRE:
It is exempted because we don't 9
feel there is -- there is no driving force to drive it out.
10 It has millions of curries, but it is not volatile materials.
11 MR. MOELLER:
And if they lost all the water in 12 the pools, and it heated up, would there be no problem?
13 I can see not covering it because it is a totally 14 different problem, but I don't understand not covering it 15 because it isn't a problem.
16 MR. McGUIRE:
What you have --
17 MR. MOELLER :
It is somewhere between Page 12 18 and 15.
19 MR. McGUIRE:
You go to page 54 in the regulatory M
analysis.
21 MR. MOELLER:
All right.
22 MR. McGUIRE:
It referenced NUREG 0709.
The 23 safety evaluation report related to renewal of material 24 license, SNM 1261 for the receipt, storage, and transfer of
(_j M
spent fuel, Morris.
_~. - - - _..,_. _. _ _.. _. _.. _ _ - _ _
.... ~.
53, 291 1
Basically, that is an accident analysis where they
()
2_
conclude that the releases under any credible scenario are 3
negligible.
4 They don' t use that word, but the doses are 5
presented on Page 56.
6 MR. MOELLER:
All right.
7 MR. McGUIRE:
Millarems.
8 MR. MOELLER:
Okay.
I missed that, so I will-9 certainly check it out.
All right.
10 MR. CORAVELLI:
Coincidentally, last night I 11 was looking at the new proposed Part 72, there are two to 12 three pages giving references of why they felt offsite 13 emergency preparedness was not required for the Morris 14 facility.
15 MR. MOELLER:
Okay.
It seems to be justified, 16 and I will look at it.
17 Now, on Page 18 of the proposed rule in the 18 upper paragraph, Line 7, you assume that the most exposed 19 individual will inhale 10 to the minus 6 of the material.
20 MR. McGUIRE:
Yes.
21 MR. MOELLER:
Now, where does that come from?
22 MR. McGUIRE:
It comes from the work of Allen 23 Broskey, who published that particular number in Health 24 Physics several years ago, giving -- looking at it from 25 different approaches.
Theoretical.
And some actually based
292 54, 1
on history of accidents.
2~
~ It really is in agreement with our calculations 3
as well.
~
'4
- MR. MOELLER:
So that is the maximum that anyone 5
would inhale, and does that have -- then it could have 6
conservatism in it.
7 Is it in your. list of conservatisms?
8 MR. McGUIRE:
That is really based on the 9
meteorology.
10 to the minus 6 is based on the F-1, adverse 10 meteorology, up to about a hundred meters, and then at that 11 point we truncate it, because we didn't feel that the 12 assumptions that would have continued this curve going up 13 were really reasonable.
14 So, really, when we look at what we are getting 15 compared to what Allen Bronsky developed, we are really 16 confirming that we agree that he is correct.
That a person 17 standing outside this facility wouldn't inhale more than 18 one one-millionth of the material that is released.
19 MR. MOELLER:
Could you put your slide of your 20 conservatisms back up and let me see where that might be 21 covered in that list?
22 (Slide.)
23 MR. PARKER:
Does that upper most curve include 24 building weight, or is there no building weight in that?
25 MR. McGUIRE:
There is a building weight in there,
293 55, 1
yes.
2 MR. MOELLER:
You add particle size --
3 you add the solubility of the particles in Part 6.
~
4 MR. McGUI RE :
Yes.
5 MR. MOELLER:
Where would we have this 10 to the 6
minus 6 number?
7 MR. McGUIRE:
Well, I guess we can say that 8
10 to the minus 6 is an adverse meteorology, but in a 9
sense truncating it at 10 to the minus 6 really doesn't to reduce the conservatism that you would get by not truncating 11 it at that point.
12 I don' t know tha t you will really call that --
(}
13
-that is a value calculated for adverse meteorology, 10 to 14 the minus 6th.
15 MR. MOELLER:
Does it apply to Number 12 also, 16 or is the 10 to the minus 6 not at the plume centerline?
17 MR. McGUIRE:
10 to the minus 6 is at the plume 18
,enterline.
19 MR. MOELLER:
It is.
Okay.
20 MR. McGUIRE:
In a sense, we make an assumption 21 really that penple in a hundred meters either -- they will l
22 move or the smoke will rise.
23 You really, in a sense, in order to maximize your l
24 intake or put a limit on your intake, you really have to invoke one of these factors within the first hundred meters.
294 56, 1
MR. MOELLER:
Okay.
I think that helps me.
O
. (,f 2
On Page 20 of the rule, you refer to the NRC and NAPOR, 3
'the naturally occurring or accelerator produced radioactive 4
material.
5 I didn't think the NRC had any jurisidiction 6
over either one of those.
7 MR. McGUIRE:
I am not exactly sure how the 8
lawyers are going to come down on that particular item, 9
but the thought was that if one needed a plan because of to licensed material that in calculating doses they should 11 add the radiation dose from the naturally occurring or 12 accelerator produced radio isotobes that could be released 13 in the same accident.
14 MR. MOELLER:
Okay.
So you are merely saying 15 include the total dose?
16 MR. McGUIRE:
Yes.
17 MR. MOELLER:
There is certainly nothing wrong 18 there.
That is the proper approach.
19 Okay.
On the NUREG 1040, I had some questions --
20 1140, excuse me.
One place -- in fact, in the proposed rule, 21 as I read it, it said the one rem is the 50 year dose from 22 inhaling this long lived material.
23 MR. McGUIRE:
Yes.
24 MR. MOELLER:
You calculate the fifty year at --
25 whatever it was, compare that to the one rem.
4 57.
295 1
MR. McGUIRE:
That is correct.
(
2 MR. MOELLER:
Well, in the NUREG 1140, in the 3
second page of the executive summary, it says that it is an
~4 eight hour dose in Line 4.
It says, you know, the first 5
sentence on Page 11, the criterion for deciding whether an 6
accident was significant enough to require the ability to 7
warn the public to take protective actions is whether a 8
release could cause a person outside the plant, on the 9
plume centerline, to receive within eight hours an effective 10 dose equivalent of more than one rem.
11 MR. McGUIRE:
Okay.
That sentence is a little 12 bit ambiguous I will tell you what that means.
The 13 eight hours really is the value that we applied to external 14 dose due to ground shine.
15 The assumption there is that even if the facility 16 didn't have a plan, that by eight hours they would realize 17 that they had an accident and they would be able to respond 18 by dose rate areas, and relocate people if necessary.
19 So, internal dose is calculated for a fifty year 20 dose commitment.
Eight hour external dose from ground shine 21 based on eight hours exposure.
22 MR. MOELLERt Okay.
That is helpful.
So, the 23 internal is still the fifty year.
24 MR. McGUIRE:
Yes.
That is a little ambigious.
O 25 MR. MOELLER:
Now, will these -- will this rulo
58.
296 1
be considered -- and this is back to wha t Frank Parker
,m
(
)
2 was asking about, will it be considered to be a backfit?
s-3 And if so, would it go to CRGR, and will it have to be shown 4
to be cost effective, which it is not.
5 MR. McGUIRE:
It would not go to CRGR because 6
it doesn' t involve reactors.
7 MR. MOELLER:
Okay.
Now, then the backfit rule 8
is only for nuclear power plants?
9 MR. McGUIRE:
Correct.
10 MR. MOELLER:
All right.
11 MR. AXTMANN:
Let it always be so.
12 MR. MOELLER:
Do we have other questions by any
,G 13 of the subcommittee members?
N]
14 MR. McGUIRE:
Let me add something on the CRGR 15 that --
16 MR. PARKER:
What is CRGR?
17 MR. McGUIRE:
That is the Committee to Review 18 Generic Requirements, headed by Vic Stello.
19 MR. MOELLER:
It is an internal NRC committee.
2 In order to try to reduce or to better organize the backfits 21 that are required, they review them and they are supposed to 22 prove that they are cost effective and so forth.
23 MR. McGUIRE:
Linwood Ross, our Deputy Director, 24 at one time said that he thought he would ask the CRGR to p~)
25 review this especially.
lie hasn' t done so at this time, and
59.
297 1
I don't know if he still intends to or not.
)
2 MR. MOELLER:
Are there other -- yes, Dick Foster.
3 MR. FOSTER:
On your final slide, you said how 4
many licensees would be effected, giving a total of 31, 5
But there are a lot more than that that have to file for 6
exemptions, is that correct?
7 MR. McGUIRE:
There would be an additional 15, 8
and it would probably lower their license limits, and another 9
15 that would probably file an exemption.
10 MR. FOSTER:
So --
11 MR. McGUIRE:
60 would be effected.
12 MR. FOSTER:
Sixty of them are going to have to
(
13 make an analysis to show whether or not they are going to havo 14 to file a plan.
15 MR. McGUIRE:
That is correct.
16 MR. FOSTER:
So, there is work to be done by 17 all of those sixty or some consultants.
18 MR. McGUIRE:
That is correct.
19 MR. FOSTER:
To como up with the reason that they 20 shouldn' t be included.
21 MR. McGUI RE:
That is correct.
22 MR. MOELLER:
And then overy agreement state 23 would have to have its agreement modified and there would 24 be, you said, five or ten licensees to agreement states who 7s
(' ')
25 would also be covered.
r 60.
298 1
MR. McGUIRE:
That is correct.
(f 2
MR. MOELLER:
And how many agreement states are 3
there?
Thirty, thirty-five.
4 MR. McGUIRE:
Twenty-seven I believe, at last 5
count.
6 MR. MOELLER:
Twenty-seven.
7 MR. McGUIRE:
Now -- agreement states only license 8
byproduct material, so we only would have seven of those 9
in that category.
10 So, we are estimating since roughly half the 11 states are agreement states, that perhaps they have another 12 seven, or round that off to five or ten.would need plans.
13 MR. MOELLER:
Any other questions?
Dick?
14 MR. FOSTER:
I guess still relative to this 15 particular one, if your criteria -- dose criteria were 16 changed from an accident level of one rem up to five rem, 17 would that significantly change the numbers of plants which 18 are involved here?
19 MR. McGUIRE:
Well --
20 MR. FOSTER:
Do you understand my question?
21 MR. McGUIRE:
Yes, I do.
No change for UF-6.
22 Criticality drops out completely.
I doubt if any of the 23 plutoniums would be offected.
They remain.
24 We might, what it would do of these seven, it O
25 would probably put about two of them on the border line, and
61.
299 1
I think if they were that close they could probably justify
(
2 some reason for going down below.
3 So, I suspect it would drop about five.
That 4
would be my guess.
5 MR. FOSTER:
Thank you.
f 6
MR. PARKER:
In your curve, the atmospheric 7
dispersion versus distance, could you sketch on that what the s
F curve with one meter per second bouyant, what the building I
i 9
weight might look like?
How much reduction you are going i
10 to have on that?
11 It should drop by about a factor of a half or so, 12 shouldn't it?
13 MR. McGUIRE:
Well, you can't have that, because j
14 if it rises it goes out of the building.
Physically, the two 15 phenomena -- if I understand you correct, the two just don't i
16 occur together, so what was your question now?
i 17 MR. PARKER:
As you get further downstream, it 1
I 18 l
depends upon how high the bouyancy goes.
18 MR. McGUIRE:
Yes.
20 MR. PARKER:
You still can have a building weight i
21 effect, not to include the adjacent to it.
As a matter of 22 fact, if I remember correctly, in the Regs it tells you just i
i 23 exactly what distances it starts to pick up to be effective.
l j
24 There is some turbulance generated by the building, 25 i
MR. McGUIRE:
Yes.
e i,_- - -.,_ - --._._.__
62.
300 1
So, it is a function of how much bouyancy you o
(_,)
2 do get, which then determines whether or not the building 3
weight is effected.
4 MR. McGUIRE:
Okay.
5 MR. PARKER:
So, it depends upon the height 6
of the bouyant plume, right?
7 MR. McGUIRE:
Yes.
I really couldn't sketch 8
anything in.
9 MR. PARKER:
I have another question.
On Page 3 to of your document, the draft document, at the end of the 11 first paragraph under 211, it says that even though you 12 have half a million licensee years, you had over five
[]
13 thousand events.
'c) 14 It seems to me you could get very good statistics, 15 but you never found any accident out of the five thousand 16 events, half a million licensee years, that ever exceeded 17 one percent of EPA's one rem protection action guide.
18 So, this is empirical evidence versus calculations 19 that you have done.
Empirical evidence says you are not N
going to come anywhere close when you swing to the -- when the 21 conservatisms drop out, these are actual values.
22 So, I guess I ask you why do you want a rule when 23 all the statistics show that it would be an extraordinarily 24 rare event that you would exceed even the one rem protective 7S
(
)
25 action guide.
'k 301 63.
1 MR. McGUIRE:
We do, in the back of this
. \\,
2 document, give some discussion of the probabilities, and 3
it does take a lot of events.
4 A person close in, standing on the plume center-5 line, adverse meteorology, large release, and we do say that i
e that is a very improbable event.
7 I would say that the statistics that we are 8
'getting are really not inconsistent with our calculations.
9 We just have been thus far fortunate that we never had all 10 the adverse effects happen simultaneously.
11 That is the same thing as saying that is 12 improbable.
' 13 MR. PARKER:
Very.
14 MR. McGUIRE:
The two really aren' t inconsistent.
15 MR. PARKER:
What you have is a low probability, 1
i
}
16 low consequence event.
That is what you are telling us.
{
17 MR. McGUIRE:
Yes.
18 MR. PARKER:
Why do they want to regulate a low 19 probability, low consequence event I guess escapen me.
20 MR. McGUIRE:
That is a very legitimate policy j
21 question, and I think it has to be answered at the Commission 22
- level, j
23 It really comes to the heart of this ruling.
1 24 MR. MOELLER:
Okay.
Any other final comments j
- O 26 or questions?
I 1
64.
302 1
(No response.)
2 There being none, I believe then we will draw 3
this meeting to a close.
Subcommittee meeting to a close 4
and we will now first thank Doctor McGuire for his time 5
this morning in presenting this proposed rule to us, and 6
we will now take a break and then we will reassemble after 7
the break in executive session to prepare in written form 8
the subcommittee's thoughts and recommendations for passing 9
on to the full committee.
10 The executive session will not be recorded, but 11 it will continue to be open to the public.
12 Thank you very much.
13 (Whereupon, the meeting concluded at 10:25 a.m.,
14 this same day.)
15 16 17 I8 4
20 21 22 23 24 25 r
i l..
1 CERTIFICATE OF QFFICIAL REPORTER 2
3 4
I 5
Thes is to certify that the attached proceedings 6
before the United States Nuclear Regulatory Commission in the 7
matter of:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 Name of proceeding:
Subcommittees on Waste Management and Site Evaluation 10 11 Cocket No.
l
'12 AIace Washington, D. C.
13 Date:
Wednesday, June 19, 1985 14 15 were held as herein a pp ea r s and that this is the original 16 transcript thereof for the file of the United States Nuclear i
17 Regulatory Commission.
rh/
13 Q,
(Signatur
,g (Typed Name of Repor'tjU() Garrett J. WA h, Jr.
20 21 22 23 Ann Miley & Associates. Ltd.
24 25
O
{
BRIEFING FOR ACRS I
i ON A F90 POSED RULE:
l c
I EERGENCY PREPAREDESS FOR FUEL CYCLE AND OTHER RADI0 ACTIVE MATERIAL LICENSEES O
BY
}
0FFICE OF NUCLEAR REGULATORY RESEARCH I
l l
JUE 19,1985 l
J l
i P
O l
r
,.,-,-,w
f BACKGROUND
.'l THE C0mlSSION IN 1980 ASKED THE STAFF TO C0r4 SIDER THE NEED FOR ADDITIONAL EMERGENCY PREPARED-NESS AT' FUEL CYCLE FACILITIES.
Iti ]98] OPDERS REQUIRING ONSITE PLANS WERE ISSUED TO CERTAIN LICEitSEES. ALSO IN 1981 AN. AINANCE NOTICC OF PROPOSED RULEMAKING WAS ISSUED ON THIS SUBJECT.
THE PROPOSED RULE WOULD CODIFY, WITH SOME MODIFICATIONS', THE 1981 ORDERS.
f THE PROPOSED RULE WOULD REQUIRE APPROXIMATELY 60 LICENSEES TO EITHER:
(1) LOWER THEIR POSSESSION LIMITS, (2) PERFCM AN EVALU4GON TO SHOW A SIGNIFICAf4T PELEASE IS NOT POSSIBLE, OR (3) SUBMIT AN EMERGENCY PLAN.
ABOUT 3G PLANS ARE EXPECTED.
THE Pf:OPOSED RULE IS CUFRENTLY SCHEDULCG TO BE SUBMITTED TO THE COMISSION: JULY 31.
4 9
e
4 iO f
WHAT ACCIDENTS AE SIGNIFICANT?
o StEDEN RUPIUE OF A LARGE EATED LF EIE 6
I ACUTE INJURIES DUE TO CEMICAL T0XICITY MAY BE POSSIBLE TO ABOUT A MIE, AClKE FATALITIES OFFSITE AE PROBABLY NOT CREDIBE, o
FIES INVOLVING BYPRODUCT MATERIALS OR PLUT0NILM NO ACUTE INJURIES OR FATALITIES O
1 REM PAG DOSE MIGHT BE EXCEEDED TO AS MJCH AS 1 MIE FOR 2 LICENSEES A AS MJCH AS 4 T0 i MIE FOR OTHERS l
0 PULSATING CRITICALITY ACCIDENT NO ACUTE INJURIES OR FATALITIES 1 REM PAG DOSE MAY BE EX&EDED TO AS MJCH AS 1/6 MIE IN 8 HOURS l
1 lO
O E=
k 3===
~
2 ASSUMPTIONS:
3 Building size: 10m x 25m.
I?elease et ground level or 20m for bouyent releases.
30-minute release duration 1 cm/sec deposition velocity 10'3
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E 10d p, 1 m Ne, N
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5
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8 5 f
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- kily, cy
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- ke Ill
' !Il Ill Illt I'll Illt lill Ill!
I'll ll'I IIII
'lli 0
200 400 soo soo 1000 1200 14 10'5 Distence. Meters Figure 1.
Atmospheric dispersion versus distance.
O O
O C0ffARIS0N OF HOW NCH DOSES WOULD BE REDUCED IN A mRE REALISTIC, TYPICAL OR ACTUAL SITilATION CONSERVATIVE FACTOR DOSE REDUCTION FACTOR 1.
ENTIRE POSSESSION LIMIT ASSUE D TO BE INVOLVED.
1 TO 10 2.
WORST-CASE RELEASE FRACTIONS 10 TO 100 FOR MORE TYPICAL FIRES 3.
NO CREDIT FOR ENGINEERED SAFEGUARDS OR 1 TO 100 IF FIRE SUPPRESSION EFFORTS ARE RESPONSE EFFORTS.
EFFECTIVE 4.
PEOPLE IN DENSE SMOKE MAKE NO EFFORT TO MOVE.
ABOUT 3 OR MORE FOR A RELISTIC RESPONSE 5.
SMOKE FROM A LARGE FIRE DOES NOT RISE.
UP TO A FACTOR OF 30 6.
WORST-CASE SOLUBILITY ASSUMED FOR PARTICILF.S.
2 TO 3 FOR MOST SIGNIFICNIT lAJCLIDES 7.
DOSES CALCULATED FOR HIGHLY RESPIRABLE ABOUT 2 8.
ADVERSE METEOROLOGY ASSUE D.
A FACTOR OF 10 COMPARED TO DOT METEOR 0GLOGY (D, 4.5 M/S) 9.
PLUE SPREAD CAUSED BY OBSTACLES IGNORED 1.2 10.
NO SHIFTS IN WIND DIRECTION 1 TO 3 11.
CRITICALITIES ASStK D TO' PULSATE FOR 8 HOURS.
3 TO 10 12.
DOSES CALCULATED FOR PLUME CENTERLINE.
ABOUT 3 FOR A RANDOMLY SITUATED PERSON.
CONCLUSION:
A RANGE OF POSSIBLE DOSES IS NOW PRESENTED IN THE REGULATORY ANALYSIS.
THE RANGE PRESENTED IS GENERALLY 1% TO 100% OF TE CONSERVATIVE OR WORST-CASE VALUES.
S 30.72 Schedule C - Quantities of Radioactive Materials Requiring Ccnsideration of the Nted for An Em;rgency Plan for Responding to a Release.
Radioactive Quantity Radioactive Quantity Material (Curies)
Material (Curies)
.t (t$0,00o) 20,000 Te-127m 5,000 H-3 C-14 1,000 Te-129m 5,000 Na-22 9,000 I-125 4 600) 7 Na-24 10,000 I-131 4 (600) 5 P-32 100 Xe-133 900,000 P-33 1,000 Cs-134 2,000 S-35 900 Cs-137 3,000 Cl-36 5,000 Ba-133 10,000 K-42 9,000 Ba-140 30,000 Ca-45 20,000 Ce-141 10,000 Sc-46 3,000 Ce-144 300 Ti-44 100 Pm-145 4,000 V-48 7,000 Pm-147 4,000 Cr-51 300,000 Sm-151 4,000 Mn-56 60,000 Eu-152 500 Fe-55 40,000 Eu-154 400 Fe-59 7,000 Eu-155 3,000 Co-60 5,000 Gd-153 5,000 Ni-63 20,000 Tb-160 4,000 Cu-64 200,000 Ho-166m 100 Zn-65 5,000 Tm-170 4,000 Ge-68 2,000 Hf-172 400 Se-75 10,000 Hf-181 7,000 Kr-85 6,000,000 Ir-192 40,000 Sr-89 3,000 Au-198 30,000 W (6M) 90 Am-243 2
Sr-90 Y-91 2,000 Cm-242 #
bInCO) 60
/8) 3 K
[ SOC)
Zr-93 400 cm-243 F
4 Zr-95 5,000 Cm-244 Nb-94 300 cm-245 2
Mo-99 30,000 Cf-252 (20 mg) 9 Tc-99 10,000 Any other beta gamma Tc-99m 400,000 emitter 10,000 Ru-106 200 Mixed fission products 1,000 Mixed corrosion products 10,000 Ag-110m 1,000 Contaminated equipment, Cd-109 1,000 beta gamma 10,000 Cd-113m 80 Irradiated materi61, In-114m 1,000 any form other trian Sn-113 10,000 solid noncombust191e 1,000 Sn-123 3,000 Irradiated material, Sn-126 1,000 solid noncombustible 10,000 Sb-124 4,000 Mixed radioactive i
l Sb-126 6,000 waste, beta gamma 1,000 Hg-203 10,000 Package mixed waste, Pb-210 8
beta gamma **
10,000 Bi-207 5,000 Any other alpha emitter 2
600 Contaminate equipment, Bi-210 $ hod 10 alpha 20 Po-210 Ac-228 4,000 Packaged waste, alpha **
20 Np-237 2
Combinations of radioactive Am-241 $ (6000) 2 materials
- listed above Am-242 2
O WHAT WOULD HAVE TO BE CONTAINED IN A LICENSFF S EK RGENCY PLAN?
(1) A brief description of the facility and site area.
(2) An identification of each type of accident for which protective actions for the public may be needed.
(3) An analysis of the potential doses to the public from each type i
of accident, including doses from naturally occurring and accelerator produced radioactive material in addition to all licensed material.
(4)
Identification of the means of detecting each type of accident in a timely manner.
(5) A brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to l
l protect workers onsite.
(6) A brief description of the methods and equipment to assess releases of radioactive materials.
O i
r
O WHAT WOULD HAVE TO BE CONTAINED IN A LIENSEE'S EE RGENCY PLAN?
(7) A brief description of the responsibilities of licensee personnel should an accident occur, including identification of personnel responsible for notifying offsite authorities and notifying the NRC.
(8) A brief description of the means of promptly notifying of off-site authorities and of requesting offsite assistance resources.
(9) A brief description of the methods for assuring that recommended protective actions and distances are unambiguously communicated to response organizations.
(10) A brief description of any special instructions the licensee would give to fire, police, medical and other emergency personn 1.
(11) A brief description of the means of restoring the facility to a safe condition after an accident.
(12) Provisions for conducting or. site drills at intervals not to exceed two years.
e O
O WHAT WOULD NOT E REQUIRED?_
NO WRITTEN STATE AND LOCAL GOVERfM NT PLANS NO STATE AND LOCAL GOVEINENT APPROVAL OF LICENSEE PLANS S
NO PUBLIC IWORMATION PROGRAMS 9
NO EERGENCY CLASSES (GENERAL EERGFKY, SITE AREA EERGENCY, ALERT) j NO EERGENCY ACTION LEVES S
NO EPZs FOR PLlfE EXPOSURE OR INGESTION 4
NO REAL-TIE DOSE PROJECTIONS 1
l 0
NO FEMA INVOLVEE NT l
l l
D lO
6 O
9 O
HOW MANY LICENSEES WOULD BE AFFECTED?
0 UF RELEASES 6
2 UF PRODUCTION PLANTS (PART 40) 6 9 LWR FUEL FABRICATION PLANTS (PART 70) 0 FIRES INVOLVING BYPRODUCT MATERIALS OR PLlHONIUM 7 BYPRODUCT MATERIAL LICENSEES (PART 30) 10 S m LICENSEES (PART 70) 0 0
CRITICAllT( (BlR NOT UF )
6 3 SNM LICENSEES (PART 70) 0 TOTAL 31 LICENSEES (IDENTICAL TO THOSE ISSUED ORDERS
?NSS)
G
~
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NUCLEAR REGULATORY COMMISSION M i 21985 10 CFR PARTS 30, 40, and 70 Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees AGENCY:
Nuclear Regulatory Commission.
ACTION:
Proposed rule.
SUMARY:
In 1981, the Nuclear Regulatory Commission (NRC) issued orders to require certain NRC fuel cycle and other radioactive material licensees to establish increased levels of emergency preparedness.
The NRC is now proposing to amend its regulations to codify those orders, but with some modifications. The proposed rule would require approximately 30 licensees to have emergency plans for responding to a release of radioactive material.
Among the requirements in the proposed rule are requirements for procedures to reduce or mitigate releases and to promptly notify offsite response organizations if an accident occurs that might cause an airborne release of radioactive material such that radiation doses offsite could exceed the lower end of EPA's protective action guide range.
DATES:
Comment period expires
- Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or before this date.
" Insert date 90 days after publication in Federal Register.
1
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ADDRESSES:
Submit written comments to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention:
Docketing and Service Branch.
Copies of comments received by the Com-mission, the Regulatory Analysis, and the environmental assessment and finding of no significant impact may be examined in the Commission's Public Document Room at 1717 H Street NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT:
Dr. Stephen A. McGuire, Regulatory Analysis and Materials Risk Branch, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555.(telephone:
301-443-7636).
BACKGROUND
~
G During the Commission's deliberations concerning nuclear power plant emergency preparedness after the Three Mile Island accident, the Commis-sion directed the staff to evaluate th,e need to change the emergency pre-paredness regulations for fuel cycle and other radioactive material" licensees.
In late 1980, the staff reevaluated previously submitted emergency plans for radioactive releases for fuel fabrication plants and found some apparent weaknesses.
For example, some plans did not describe recommendations for specific protective actions for the public, such as sheltering or evacuation, and arrangements for prompt notification of offsite response organizations.
Upon noting these weaknesses, the NRC staff prepared orders requiring 62 licensees to submit comprehensive onsite radiological contingency plans (46 FR 12566).
These orders, which were issued in February 1981, required 2
[7590-01]
some licensees, based on their licensed possession limits, to plan for actions that would be needed in the event of an accident.
The actions would be those necessary to:
protect workers, limit the release of radioactive materials, and mitigate adverse consequences of the accident.
The orders were issued to operators of fuel processing and fabrication plants, UFs production plants, and radioactive material users authorized to possess large quantities of radioactive materials in unsealed form.
The licensees selected were those authorized to possess quantities of radioactive materials that could as a result of a severe accident poten-tially result in a radiation exposure in excess of 1 rem effective dose equivalent to someone offsite.
As a result of these orders, about half of the affected licensees reduced their authorized possession limits for radioactive material, thus no longer requiring them to submit contingency OO plans to NRC.
On June 3, 1981, the Commission published in the Federal Register (46 FR 29712) an advance notice of proposed rulemaking on emergency pre-paredness for certain fuel cycle and other radioactive material licensees.
In this advance notice, the Commission proposed to codify the radiological contingency planning requirements set forth in their orders, as well as consider offsite preparedness.
The Commission noted in the advance notice that they would use factors such as possession limits, potential for acci-dential criticality, chemical toxicity of radioactive materials, and potential radiation hazards for all of the NRC licensees whose radioactive material possession limits were such that severe accidents could result in offsite radiation doses exceeding the lower end of the protective action guides established by the EPA.
O 3
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PUBLIC COMMENTS ON THE ADVANCE NOTICE The Commission, in the advance notice, requested public comments and received 18 responses.
Comments were received from five Federal agencies, four State agencies, five corporations, one university, one laboratory, one non profit Federal corporation, and the Conference of Radiation Control Program Directors.
The following discussion summarizes the major comments and gives the Commission's response to each comment.
Comment.
Many commentors questioned the need for the suggested regulations.
One Agreement State said there is "...little likelihood of a serious acci-dent; those incidents which have occurred have been handled adequately without pre-existing plans, using existing resources and guidelines."
Commentors said that many of the facilities that would be covered do not have the potential to exceed the EPA's protective action guide dose of 1 rem under any credible accident conditions.
Uranium mills, UFs conver-sion plants, and low level waste burial grounds were cited by commenters as examples. Another example where emergency plans were not considered necessary was the case in which the radioactive materials are spread among many different buildings so that release of a large proportion due l
to a single event is not credible.
Several commentors said NRC already requires them to be adequately prepared to respond to an emergency, and that there is no need for additional regulations.
The Agreement States of New Mexico and Washington said they were already adequately prepared for any credible accident and saw no need for a regulation.
On the other 4
[7590-01]
i hand, the State of New York saw a need to reevaluate the adequacy of its 1
existing emergcncy planning.
One commentor said the need for the regula-tion should be tested against past accident experience to determine the urgency and realism of the proposal.
Another commentor said that, compared to nuclear power plants, fuel cycle and byproduct material licensees have much less radioactive material, do not have a large energy supply to act as a driving force and do not concentrate their radioactive materials in a single location.
Thus the consequence of an accident would be much smaller, and there would never be a need to evacuate or shelter people.
l l
Response.
l l
The NRC has carefully analyzed accident source terms, potential release fractions, and radiation doses attributable to a range of acci-dents at fuel cycle and other radioactive material licensees.
The details l
are given in "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and other Radioactive Material L.icensees," NUREG-1140.1 Specific j
conservative accident scenarios have been considered for specific types l
of licensees, and release fractions and doses have been calculated based on these scenarios.
The accident history of different types of facilities has been considered.
As a result of'the analysis some facilities, such as uranium mills, are excluded from needing an emergency plan for respond-ing to a release.
On the other hand, the analysis does indicate that, at a few licensed facilities, offsite doses due to an accident might exceed i
i 1 Single copies are available without charge upon written request from:
NRC Sales Office, NRC, Washington, DC 20555.
1 5
i
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the lower end of the range of doses for which the EPA recommends that protective actions to protect the public be considered.
The NRC would especially like to receive comments on the accident scenarios presented in the analysis.
The NRC is particularly interested in comments concern-ing the conservatism in the analysis as it pertains to specific classes of facilities.
Comment.
A second major comment was that the need for emergency plans should be evaluated on a case-by-case basis.
Several examples were given wherein the licensed possession limits might indicate the need for a plan, but the actual circumstances would make a large release impossible.
For example, a radiopharmaceutical manufacturer said that they use only a small quantity of. their iodine-125 at one time.
The rest is stored in l
l lead containers in a fume hood, the air from which is filtered three times l
before release.
Commentors said the remoteness of the site should be a factor taken into consideration.
In the case of one uranium mill, the nearest residence is 22 miles away.
The comment was made that case-by-case l
review of the need for plans is feasible because so few licensees would be affected.
Response.
The proposed rule would allow licensees the opportunity to demon-strate that an emergency plan for responding to a release would not be needed because no credible accident could result in doses to the public approaching the protective action guides.
6
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Comment.
Several commentors thought FEMA review of State and local emergency response capabilities was unnecessary because possible accidents would be so much smaller than at nuclear power plants.
It was said that simpler, less complex review and evaluation processes were better.
Several Agree-ment States objected to a FEMA review of their programs.
Other commentors thought FEMA could make valuable contributions.
Response.
The NRC has considered the nature and depth of the needed offsite coordination in the previously mentioned Regulatory Analysis and concluded that written site-spacific State and local plans reviewed by FEMA are not needed because the accidents can be responded to as part of the community's general emergency response capabil'ities.
These necassary capabilities (e.g., fire, ambulance, police support) are routinely used for emergencies of all sorts.
The small potential doses, small areas affected, small num-I bers of people involved, and quick response times needed are factors indicating that the community's normally existing emergency response capabilities are adequate and that additional response capabilities are not necessary.
Comment.
Some commentors thought failure of uranium mill tailing dams should O
be included.
7
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Response.
The NRC has considered such events and concluded that they should not be included because radiation doses associated with such accidents are so low that EPA protective action guides would not be exceeded even over a very long time (months or years).
A complete explanation is presented in "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," NUREG-1140.1 Comment.
Many commentors thought the NRC should provide a document describing the contents of the licensee's emergency plans and the nature of the pre-paredness needed.
Response.
The NRC agrees and plans to revise its reports, NUREG-0762, " Standard Format and Content for Radiological Contingency Plans for Fuel Cycle and Materials Licensees," and NUREG-0810, " Standard Review Plan for the Review of Radiological Contingency Plans for Fuel Cycle and Materials Facilities." The revised reports would be published, possibly as Regula-tory Guides, concurrently with the final rule.
O 8
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O Comment.
O Several commentors thought the suggested regulations would be burden-some and expensive to both licensees and to States and that the cost would greatly exceed the benefits.
Response.
T The NRC considers that the rule as proposed would not be expensive and burdensome to States or local governments.
States and local govern-ments would not be expected to write specific plans for specific facili-ties or have other special emergency preparedness.
The NRC considers the normally available capabilities of States and local governments for responding to industrial emergencies and the normally available radio-logical health capabilities of States adequate to deal with accidents at fuel cycle and other radioactive material licensees.
These radiological emergencies would involve small (not life threatening) doses, small areas, and small numbers of people.
The potential risks are much lower than the risks from accidents involving chemical plants or the shipping of hazar-dous chemicals, to which States and local governments routinely respond.
1 In other words, the response to radiological accidents at fuel cycle and other radioactive materials licensees can and should be handled by State and local governments as part of its normal emergency response capability without additional resources.
Thus, an adequate level of emergency pre-paredness should not be a financial burden to State and local governments.
- O 9
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With regard to benefits, the benefits are admittedly small because of the low probability of exceeding protective action guide doses and the low probability that a dose of a few rems would have harmful consequences.
Costs to licensees were found to significantly exceed potential benefits (see Regulatory Analysis, Section 3).
However, the Commission considers that the protection provided by engineered safety features should be bolstered by the ability to promptly notify offsite authorities if an accident occurs so that protective actions can be taken should they be needed.
Comment.
Several commentors thought NRC should provide funding to States for State planning.
Response.
The NRC sees no need for funding for State planning because a need for additional site-specific state planning was not identified.
Ccmment.
Several commentors objected to the way in which EPA's protective action guides were applied.
They said the whole body guide was actually a 1 rem to 5 rem range, whereas the NRC arbitrarily selected 1 rem.
O 10
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Response.
(
The NRC considers 1 rem as the point at which planning should begin.
The potential releases are relatively small, and the areas and numbers of people involved are small.
Thus, it is practical to consider actions at the lower end of the protective action guide range.
Comment.
Other commentors said that the ICRP Publication 26 methodology should be used to determine the protective action guides for radioactive materials that are inhaled and deposited in the body.
Response.
The ICRP Publication 26 methodology has been used.
Comment.
One commentor said Part 72 spent fuel storage licensees should be covered under the regulation.
Response.
The need for licensee emergency procedures for accidental releases by Part 72 licensees is being considered in a separate rulemaking scheduled O
to be published for public comment in late 1985.
Part 72 licensees were 11
[7590-01]
found not to need emergency plans for responding to accidental releases because potential offsite doses would not exceed EPA's protective action guides and thus no response would be needed by the public.
The analysis to support this finding is contained in the Regulatory Analysis.1 Comment.
One commentor said sealed sources should be covered under this regu-lation.
Response.
The NRC considers that there is no need to include sealed sources in t'his rulemaking because sealed source accidents are already adequately dealt with in other parts of the regulations.
(See, for example, S 20.402(a), $20.403, S 30.33(a)(2), S 34.25, S 34.32(g) and (h), and S70.60).
In addition, based on the history of accidents involving sealed sources at licensed facilities, the NRC finds that additional emergency preparedness beyond that now existing at these facilities is not warrented.
However, the NRC is uncertain about whether it should include in its rulemaking foils, plated sources, thin-window sealed sources (such as those sometimes used for americium-241) and sealed sources using low-melt-ing temperature metal such as aluminium.
The NRC specifically requests experimental information or other analyses that will help it decide the question.
O 12
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Comment.
The co:went was made that a large number of byproduct material licensees do not list the specific radionuclides they will possess, but only a total curie limit for classes of nuclides, for example those with atomic numbers 3 through 83.
(This approach is recommended in Regulatory Guide 10.5, " Applications for Type A License of Broad Scope," Item 8A and Item 80.) This makes it impossible to determine, based on possession limits, whether extensive emergency preparedness is really appropriate.
Response.
The NRC will not require emergency plans for a facility unless a plausible accidental release of radioactive materials could cause doses to the public exceeding protective action guides.
If a licensee woulc be covered by the rule because the licensee is authorized to possess material he does not possess and has no intention of possessing in the future, tne obvious solution is for the licensee to request a license amendment to l
reduce the licensed possession limit.
If the licensee actually possesses l
or may possess in the future enough material to be covered by the regula-I tion, but there are site specific reasons why a significant release is not plausible, the proposed rule would allow the licensee to demonstrate this, i
i THE PROPOSED RULE i
i The Commission is proposing these amendments to 10 CFR Parts 30, 40, f
and 70 on emergency preparedness.
The proposed rule would cover fuel 13
[759n-01]
cycle and other radioactive material licensees which may have the potential for accidents that could result in radiation doses to the public that exceed the lower end of the EPA's protective action guides or could result in injury due to chemical toxicity.
These proposed regulations would require certain lir.1 sees to maintain emergency plans for responding to such acci-dents.
The proposed requirements are similar to current NRC's emergency preparedness requirements for research reactors because potential releases and their associated doses to the public are relatively small in both cases.
The criteria selected for establishing whether a licensed facility would be required to establish and maintain special emergency plans for accidental releases is whether a severe accident could deliver a radia-tion dose of 1 rem effective dose equivalent, 5 rems to the thyroid, or soluble uranium intake exceeding 2 milligrams to a member of the public.
The EPA recommends that actions to protect the public be considered if projected whole body doses due to an accident are in the range of 1 to 5 rems, taking into account the practicality of the actions that would be taken.
The proposed rule uses the 1-rem low end of the dose range as the criteria for establishing whether a licensed facility needs an emer-gency plan for responding to a release.
In addition, conservative assump-tions have been used to estimate the doses which could result from an accident.
Doses that would result from an actual accident would prob' ably be well below the calculated doses on which the regulation is based.
The EPA's draft protective action guides apply to radiation received uniformly over the body.
These guidelines are not applicable if the radiation dose is not uniform or if only some body organs receive the radiation dose. To account for radionuclides that are deposited nonuni-formly in the body, such as those possessed by fuel cycle and other 14 J
[7590-01]
radioactive material licensees, the effective dose equivalent from these radionuclides is used to replace the whole body dose equivalent.
The effective dose equivalent is defined as the sum of the external radiation dose equivalent plus the dose equivalent to each body organ due to radioactivity deposited within the body multiplied by a risk weighting factor for the organ.
The weighting factors are taken from Publication 26 of the International Commission on Radiological Protection.
The conservative accident scenarios and dose calculations which form the technical basis for the proposed rule are described in detail in the previously mentioned, " Regulatory Analysis of Emergency. Preparedness for Fuel Cycle and Other Radioactive Material Licensees," NUREG-1140, which is available upon request.1 Except for radioiodine doses, which are calculated for children, doses are calculated for an average adult.
Doses to children would be slightly different due to differences in their metabolisms.
Unfortunately, doses to children have not been calculated for the modern ICRP Publica-tion 26 dosimetric models except for a few radionuclides.
The NRC con-siders the differences between adult doses and child doses to be insignif-icant in comparison with the other uncertainties in the analysis.
The NRC also considers that the inherent conservatism in its accident dose calculations and its use of the 1-rem lower end of the range for protec-tive action consideration provide an adequate margin of safety.
Public comments on this item are specifically requested.
For most licensees who would be required to establish and maintain a plan, the degree of risk is small.
For most licensees, even worst-case doses to an individual on the plume centerline resulting at any distance are less than 5 or 10 rems.
The areas where people should take protective 15
[7590-01]
actions in case of an accident are small, generally a few city blocks around a facility.
For most licensees the area where doses could exceed protective action guides would be no more than a few-hundredths of a square mile.
Finally, the probability of a major release is small - less than 10 4/yr, and the probability of a major release simultaneous with highly adverse meteorology is less than 10.s/yr.
Details are provided in the Regulatory Analysis, Sections 2.4, 2.5, and 3.
The rupture of a large heated cylinder of UFs is an exception in that the consequences due to the chemical toxicity of the released material could be of greater concern than the radiation doses from any plausible accident at fuel cycle or other radioactive material facilities.
Airborne releases due to a severe accident at these licensed facili-ties are likely to occur rapidly with little warning.
The only types of accidents identified for which protective actions might be needed for the public are a fire, a UF8 cylinder rupture, and a criticality accident.
Releases from a fire could start even before the fire is detected or shortly thereafter.
Plume travel time to nearby people is likely to be no more than a few minutes.
Releases would usually end within half an hour to an hour when the local fire department has controlled the fire.
As a result, protective actions would have to be taken quickly to be effective.
Thus, NRC proposes that predetermined actions to be recom-mended for people at or near the site such as firemen, policemen, and nightwatchmen at the plant.
Police departments and fire departments are experienced and capable of providing the types of onsite emergency responses appropriate and are also capable of extending responses beyond the facility property should such a need arise.
Due to the rapid progression of the O
16
[7590-01]
tm
(]
accidents of concern, the NRC considers the use of real-time dose projec-tions and complicated decisionmaking to be inappropriate during an actual emergency.
Instead predetermined actions and decisions should be developed in coordination with offsite response organizations.
The proposed amendments to Parts 30, 40 and 70 would require that licensees authorized to possess in excess of certain quantities of by-product materials, source materials, and special nuclear materials evaluate potential doses from a severe accident and submit emergency plans for responding to releases if an evaluation shows it is needed.
The proposed rule would also cover any future plutonium fuel fabrication l
plants.
The table of quantities that would require evaluation of the need for an emergency plan was taken from "A Regulatory Analysis of Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees,"
The table lists quantities that might deliver an effective dose equivalent of 1 rem to the public in the event of a severe accident.
The quantities were calculated by assuming that the most exposed member of the public would inhale a fraction of 10 8 of those materials with no l
ground deposition and about 10% less of those materials that deposit do on the ground.
External doses from cloudshine and groundshine are then added to the internal dose.
The 1-rem effective dose equivalent is a 50 year dose commitment calculated by ths methods of ICRP Publications 26, 28, and 30.
The table includes all nuclides listed on 20 or more of NRC's approx-imately 9000 licenses, except for I-129.
I-129 was not included because saturation would prevent the thyroid from absorbing enough I-129 to reach
\\
the 5 rem protective action guide for thyroid dose.
The table also includes 17
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all beta gamma emitters listed on any license for which the quantity to deliver a 1-rem effective dose equivalent would be less than 10,000 curies.
The table includes all alpha emitters listed on any license for which the quantity to deliver a 1-rem effective dose equivalent would be less than 2 curies.
The quantities in the table are different from quantities previously published in NUREG-0767, " Criteria for Selection of Fuel Cycle and Major Materials Licensees Needing Radiological Contingency Plans," Federal Register Notices with Orders to Licensees (46 FR 12566), and an Advance Notice of Rulemaking (46 FR 29712).
The main reasons for the differences are:
(1) dosimetric models from ICRP Publication's 26, 28, and 30 have been used instead of the older models from ICRP Publication 2; and (2) release fractions have changed as the result of further study.
The intercept fraction remains 10 8 for nondepositing radionuclides.
In addi-tion, two new pathways, external radiation from groundshine and from cloudshine, are included.
Licensees are given the option of demonstrating that emergency plans for responding to accidental releases are not needed because doses to the public would not exceed 1 rem effective dose equivalent as a result of a credible accident at their specific facility.
The table of radio-nuclides in the proposed regulations was developed using conservative, pessimistic, or " worst-case" assumptions.
Each assumption is possible at some " generic" facility, but may not be realistic for a specific actual facility.
Thus the licensee is given the option of analyzing accidents for the actual existing facility and determining site-specific maximum releases.
If the resulting doses are below 1 rem, an emergency plan for responding to the release would not be required.
18
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The licensee also has the option of revising facility design, operat-ing procedures, or possession limits to reduce potential doses to the public below 1 rem effective dose equivalent in lieu of preparing an emer-gency plan for responding to an accidental release.
If an emergency plan for responding to an accidental release is needed, it would include:
(1) A brief description of the facility and site area.
The purpose is to provide the reader with enough basic information to evaluate the licensee's pian.
Significant facilities, such as schools, for which protective actions might be appropriate should be included in the site area description.
(2) An identification of each type of accident for which protective actions for the public might be needed.
Typically, the accidents of con-cern are fires involving radioactive materials, releases of large quan-l tities of uranium hexafluoride, and criticalities involving high-enriched uranium or plutonium.
l (3) An analysis of the potential doses to the public from each type of accident, including doses from naturally occurring or accelerator pro-duced radioactive material (NARM) in addition to licensed material.
This analysis should include dose vs. distance curves.
Data to calculate the i
curves are contained in the Regulatory Analysis for this proposed rule, NUREG-1140.
(4)
Identification of the means of detecting each type of acci-dent in a timely manner.
The means of detection could include one or more of the following:
fire alarms, criticality alarms, visual observation, or I
radiation monitors, as appropriate.
t l
19 l
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s
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(5)
A. brief description of the mr.ans and equipment for mitigating th$'consequencesofeachtypeofaccident,'includingthoseprovidedto
' protect worktirs onsite.
Mitigating actions could include actions to s
' reduce or stop the release and actions to protect workers by means such i
as evacuation of the building or decontamination of personnel.
Means for
^
limiting releases could include sprinkler systems and other fire suppres-sion systems, fire detection systems, physical separation of uaterial, storage in fire-resistant cor.tuiners, use of fire resistant building i
materials, fire-fighting capabilitin, procedures prohibiting flammable materials in areas where radioactive materials are found, filter systems, use of water sprays to knock-down UFe,' and others.
Equipm t might include respiratory protection equipment, evacuation
,a arms, and hquipment possessed by the licensee to reduce or stop the l
release. ' It would not' include equipment brought to the site by offsite respcnse organizations.
Only special equipment unique to firefighting at.the.particular facility should be identified.
'This item-is not intended to require backfits or design changes.
Plant design is subject to a inure complete safety review when the license application in reviewed.
(6) A brief description of the nethods and equipment to assess releases of radioactive materials.
This does not mean real-time assess-reent.
It is assumed that measure >nent will generally only be feasible after
+
the release has occured.
~
(7) A brief description cf the responsibilities of licenseeLpersonnel
'should an accfdent o.: cur, including the identification of personnel notify-ing offsite authorit.{es and. notifying the NRC.
Offsite authorities would generally include fire, police, and medical personnel.
The licensee need 20
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i not notify the State unless the State is assigned some essential and
%)
urgent function.
(8) A brief description of the means of promptly notifying of fsite authorities and of requesting offsite assistance resources.
Notification would most commonly be by telephone.
In a few caset, the licensee may want to seek assistance from the Department of Energy under the Federal Radiological Emergency Response Plan (see 49 Federal Register 3578, January 27, 1984).
(9)
A brief description of the methods for assuring that recommended protective actions and distances are unambiguously communicated to response organizations.
The licensee, in coordination with offsite authorities, should decide on recommended protective actions and distances in advance.
They should be written so that they may be read to offsite authorities ha by nontechnical personnel.
(10) A brief description of any special instructions the licensae would give to fire, police, medical, and other emergency personnel.
Such instructions on how to deal with the radiation release should be appropriate for the personnel and should clearly state the specific actions expected of them and things they should or should not do.
(11) A brief description of the means of restoring the facility to a safe condition after an accident.
Detailed procedures are not appropriate because the exact nature of the accident cannot be forseen.
Instead general criteria are appropriate.
(12) Provisions for conducting onsite drills at intervals not to exceed two years.
The drills are for the purpose of familiarizing the licensee personnel with the emergency plan and training them in the use O
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of site-specific response procedures.
Participation by offsite personnel e
is not required (nor prohibited).
The NRC has also considered the need for formal public information programs for people living close to licensed facilities who might be advised to take protective actions if an accident occurred.
The NRC could not identify any compelling need for such programs but is willing to consider the need for public information programs and include a require-ment for them in the final rule if such a need could be established by public comments.
Most if not all of the licensees who would be required to submit an emergency plan by this regulation have already submitt<:d onsite Radio-logical Contingency Plans under the orders issued in 1981.
Those plans already include much of the information that would be required under the new regulation. The NRC woulo not expect those licensees to rewrite those Rather it would be acceptable to submit a supplement to the Radio-plans.
logical Contingency Plan that contained any information now required that is not already in the Radiological Contingency Plan.
In its review of the licensee's emergency plan, the NRC will consult with FEMA under the terms of the FEMA-NRC memorandum of understanding as appropriate on a case-by-case basis.
The staff identified 62 NRC licensees who would be covered by the rule as proposed.
It is likely, however, that about 16 of those licensees would lower their possession limits so they would not be covered and that Realis-about 15 would demonstrate that the 1-rem dose is not plausible.
tically, probably no more than about 31 licensees would actually be required to submit an emergency plan.
Perhaps about 5 to 10 Agreement State licensees would also eventually be covered because the new requirements would be a matter of compatability with Agreement States.
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FINDING OF NO SIGNIFICANT ENVIRONMENTAL IMPACT: AVAILABILITY
(
The Commission has determined under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Subpart A of 10 CFR Part 51, that this rule, if adopted, would not be a major Federal action significantly affecting the quality of the human environment and therefore an environmental impact statement is not required.
The rule would not affect the probability or the size of accidental radioactive releases.
It might in some cases reduce the doses people near the facility site could receive.
The environmental assessment and finding of no significant impact on which this deter-mination is based are available for inspection at the NRC Public Document Room, 1717 H Street NW., Washington, DC.
The environmental
()
assessment and finding of no significant impact are contained in Sec-tion 4.3 of "A Regulatory Analysis for Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," NUREG-1140. Single copies are available without charge upon written request from NRC Sales Office, NRC, Washington, DC 20555.
PAPERWORK REDUCTION ACT STATEMENT This proposed rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
This rule has been submitted to the Office of Management and Budget for review and approval of the paperwork requirements.
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REGULATORY ANALYSIS The Comission has prepared a regulatory analysis on this proposed regulation.
The analysis examines the accident scenarios considered by the Commission as well as the costs and benefits of alternative actions considered.
The analysis is available for inspection in the NRC Public Document Room, 1717 H Street NW., Washington, DC.
Single copies of the analysis (NUREG-1140) may be obtained without charge upon written request from:
NRC Sales Office, U.S. Nuclear Regulatory Comission, Washington, DC 20555.
As indicated previously, the Commission is particularly interested in receiving public comments on the regulatory analysis.
Comments on the analysis may be submitted to the NRC as indicated under the ADDRESSES heading.
REGULATORY FLEXIBILITY CERTIFICATION As required by the Regulatory Flexibility Act of 1980, 5 U.S.C.
605(b), the Commission certifies that this rule, if adopted, will not have a significant economic impact upon a substantial number of small entities.
A small entity has been defined as one with gross receipts under $1,000,000/ year.
No such entities would be covered under the proposed rule.
Any small entity subject to this regulation which determines that, because of its size, it is likely to bear a disproportionate adverse eco-nomic impact should notify the Commission of this in a comment that indi-cates the following:
24
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a.
The size of their business and how the proposed regulations would result in a significant economic burden upon them as compared to larger organizations in the same business community.
b.
How the proposed regulations could be modified to take into account their differing needs or capabilities.
c.
The benefits that would accrue, or the detriments that would be j
avoided, if the proposed regulations were modified as suggested by the commentor.
d.
How the proposed regulations, as modified, would more closely equalize the impact of NRC regulations or create more equal access to the benefits of Federal programs as opposed to providing special advantages 1
to any individuals or groups, 4
i e.
How the proposed regulations, as modified, would still ade-1 quately protect the public health and safety.
The comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555, ATTN:
Docketing and Service Branch.
LIST OF SUBJECTS FOR 10 CFR PARTS 30, 40, AND 70 1
i Part 30 - Byproduct material, Government contracts, Intergovernmental relations, Isotopes, Nuclear materials, Penalty, Radiation protection, Reporting and recordkeeping requirements.
Part 40 - Government contracts, Hazardous materials - transportation, Nuclear materials, Penalty, Reporting and Recordkeeping requirements, Source material, Uranium.
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Part 70 - Hazardous materials - transportation, Nuclear materials, Packaging and containers, Penalty, Radiation, Reporting and recordkeeping requirements, Scientific equipment, Security measures, Special nuclear material.
Under the authority of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments to 10 CFR Parts 30, 40, and 70.
PART 30 - RULES OF GENERAL APPLICABILITY TO DOMESTIC LICENSING OF BYPRODUCT MATERIAL 1.
The authority citation for Part 30 is revised to read as follows:
O AUTHORITY:
Secs. 81, 82, 161, 182, 183, 186, 68 Stat. 935, 948, 953, 954, 955, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C.
2111, 2112, 2201, 2232, 2233, 2236, 2282); secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, 1244, 1246 (42 U.S.C. 5841, 5842, 5846).
Section 30.7 also issued under Pub. L.95-601, sec. 10, 92 Stat.
2951 (42 U.S.C. 5851).
Section 30.34(b) also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.C. 2234).
Section 30.61 also issued under sec. 187, 68 Stat. 955 (52 U.S.C. 2237).
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.
2273); SS 30.3, 30.34(b) and (c), 30.41(a) and (c) and 30.53 are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); and SS 30.36, 30.51, 30.52, 30.55, and 30.56(b) and (c) are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
26 1
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Q'3 2.
A new S 30.35 is added to read as follows:
S 30.35 Emergency plans.
(a) Each licensee authorized to possess radioactive materials in unsealed form, on foils or plated sources, or sealed in glass in excess of the quantities in S 30.72, " Schedule C - Quantities of Radioactive Materials Requiring Consideration of Need for an Emergency Plan for Responding to a Release," shall submit either:
(1) An evaluation showing that the maximum dose to a person offsite due to a credible release of radioactive materials would not exceed 1 rem effective dose equivalent; or (2) An emergency plan for responding to a release of radioactive material.
(b) An evaluation submitted under paragraph (a)(1) may include D
consideration of the following factors:
(1) The radioactive material is physically separated so that only a portion could be involved in an accident.
(2) All or part of the radioactive material is not subject to release during an accident because of the way it is stored or packaged.
(3) The release fraction in the respirable size range would be lower than the release fraction assumed in developing S 30.72 due to the chemical or physical form of the material.
(4) The solubility of the radioactive material would be different than the solubility assumed in developing S 30.72.
(5) Facility design or engineered safety features in the facility would reduce a release to lower values than those assumed in developing S30.72, O
27
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(6) Operating restrictions or procedures would prevent a release as large as the released assumed in developing 9 30.72.
(7) Other factors appropriate for the specific facility.
(c) An emergency plan for responding to a release of radioactive material submitted under paragraph (a)(2) of this section must include the following information:
(1) A brief description of the facility and site area.
(2) An identification of each type of accident for which protective actions for the public may be needed.
(3) An analysis of the potential doses to the public from each type of accident, including doses from naturally occurring and accelerator produced radioactive material in addition to all licensed material.
(4) Identification of the means of detecting each type of accident in a timely manner.
(5) A brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to protect workers onsite.
(6) A brief description of the methods and equipment to assess releases of radioactive materials.
(7) A brief description of the responsibilities of licensee personnel should an accident occur, including identification of personnel responsible for notifying offsite authorities and notifying the NRC.
(8) A brief description of the means of promptly notifying of off-site authorities and of requesting offsite assistance resources.
(9) A brief description of the metheds for assuring that recommended protective actions and distances are unambiguously communicated to response organizations.
28
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(10)
A brief description of any special instructions the licensee would give to fire, police, medical and other emergency personnel.
(11)
A brief description of the means of restoring the facility to a safe condition after an accident.
(12)
Provisions for conducting onsite drills at intervals not to exceed two years.
(d)
The licensee shall allow the local governmental authorities expected to respond in case of an accident 60 days to comment on the licensee's emergency plan before submitting it to NRC.
The licensee shall submit any comments received within the 60 days to the NRC with the emergency plan.
3.
A new $ 30.72 is added to read as follows:
S 30.72 Schedule C - Quantities of Radioactive Materials Requirina Consideration of the Need for An Emergency Plan for Respondina to a Release.
Radioac.tive Quantity Radioactive Quantity Material (Curies)
Material (Curies)
H-3 20,000 Te-127m 5,000 C-14 1,000 Te-129m Na-22 5,000 9,000 1-125 Na-24 7
10,000 1-131 P-32 5
100 Xe-133 900,000 P-33 1,000 Cs-134 S-35 2,000 900 Cs-137 Cl-36 3,000 5,000 Ba-133 K-42 10,000 9,000 Ba-140 Ca-45 30,000 20,000 Ce-141 10,000 Sc-46 3,000 Ce-144 Ti-44 300 100 Pm-145 V-48 4,000 7,000 Pm-147 1
Cr-51 4,000 300,000 Sm-151 4,000 Mn-56 60,000 Eu-152 Fe-55 500 40,000 Eu-154 400 29
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Radioactive Quantity Radioactive Quantity Material (Curies)
Material (Curies)
Fe-59 7,000 Eu-155 3,000 Co-60 5,000 Gd-153 5,000 Ni-63 20,000 Tb-160 4,000 Cu-64 200,000 Ho-166m 100 Zn-65 5,000 Tm-170 4,000 Ge-68 2,000 Hf-172 400 Se-75 10,000 Hf-181 7,000 Kr-85 6,000,000 Ir-192 40,000 Sr-89 3,000 Au-198 30,000 Sr-90 90 Am-243 2
Y-91 2,000 Cm-242 60 Zr-93 400 Cm-243 3
Zr-95 5,000 cm-244 4
Nb-94 300 Cm-245 2
Mo-99 30,000 Cf-252 (20 mg) 9 Tc-99 10,000 Any other beta gama Tc-99m 400,000 emitter 10,000 Ru-106 200 Mixed fission products 1,000 Mixed corrosion products 10,000 Ag-110m 1,000 Contaminated equipment, Cd-109 1,000 beta gama 10,000 Cd-113m 80 Irradiated material, In-114m 1,000 any form other than Sn-113 10,000 solid noncombustible 1,000 Sn-123 3,000 Irradiated material, Sn-126 1,000 solid noncombustible 10,000 Sb-124 4,000 Mixed radioactive Sb-126 6,000 waste, beta gama 1,000 Hg-203 10,000 Package mixed waste, Pb-210 8
beta gama**
10,000 B1-207 5,000 Any other alpha emitter 2
B1-210 600 Contaminate equipment, Po-210 10 alpha 20 Ac-228 4,000 Packaged waste, alpha **
20 Np-237 2
Combinations of radioactive Am-241 2
materials
- listed above Am-242 2
- For combinations of radioactive materials, an emergency plan is required if the sum of the quantity of each radioactive material authorized divided by the quantity for the material in Schedule C exceeds unity.
- Waste packaged in Type B containers does not require an emergency plan.
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i
)
PART 40 - DOMESTIC LICENSING OF SOURCE MATERIAL 4
4.
The authority citation for Part 40 continues to read as follows:
AUTHORITY:
Secs. 62, 63, 64, 65, 81, 161, 182, 183, 186, 68 Stat.
932, 933, 935, 948, 953, 954, 955, as amended secs. 11e(2), 83, 84, Pub.
L.95-604, 92 Stat. 3033, as amended, 3039, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2014(e)(2), 2092, 2093, 2094, 2095, 2111, 2113, 2114, 2201, 2232, 2233, 2236, 2282); sec. 274, Pub. L.86-373 Stat. 688 (42 i
U.S.C. 2021); secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, 1244, 1246 (42 U.S.C. 5841, 5842, 5846).
Section 40.7 also issued under Pub. L.95-601, sec. 10, 92 Stat.
2951 (42 U.S.C. 5851).
Section 40.31(g) also issued under sec. 122, 68 Stat. 939 (42 U.S.C. 2152).
Section 40.46 also issued under sec 184, 68 Stat. 954, as amended (42 U.S.C. 2234).
Section 40.71 also issued under sec 187, 68 Stat. 955 (42 U.S.C. 2237).
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.
I 2273); SS 40.3, 40.25(d)(1)-(3), 40.35(a)-(d), 40.41(b) and (c), 40.46, 40.51(a) and (c) and 40.63 are issued under sec. 161b, 68 Stat. 948, I
as amended (42 U.S.C. 2201(b)); and SS 40.25(c) and (d)(3) and (4).
{
40.26(c)(2), 40.35(e), 40.42, 40.61, 40.62, 40.64, and 40.65 are issued l
under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
l 31
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5.
A new paragraph (i) is added to S 40.31 to read as follows:
6 40.31 Applications for specific licenses.
A A
A A
A (i)(1) Each licensee authorized to possess uranium hexafluoride in excess of 50 kg in a single container or 1000 kg total shall submit either an evaluation showing that the maximum intake of soluble uranium by a member of the public due to an accident would not exceed 2 mg or an emergency plan for responding to a release.
An evaluation may include consideration of the following factors:
(1) All or part of the radioactive material is not subject to release during an accident because of the way it'is stored or packaged.
(ii) Facility design or engineered safety features in the facility would reduce the amount of the release.
(iii) Other factors appropriate for the specific facility.
(2) An emergency plan submitted under paragraph (i)(1) of this section must include the following:
(i) A brief description of the, facility and site area.
(ii) An identification of each type of accident for which protective actions for the public may be needed.
(iii) An analysis of the potential exposures to the public from toxic licensed materials for each type of' accident.
(iv)
Identification of the means of detecting each type of accident in a timely manner.
(v) A brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to protect workers onsite.
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(vi) A brief description of the methods and equipment to assess off-U site releases of radioactive materials.
(vii) A brief description of the responsibilities of licensee personnel should the accident occur, including identification of personnel responsible for_ notifying offsite authorities and notifying the NRC.
(viii) A brief description of the means of promptly notifying of off-site authorities and of requesting offsite assistance resources.
(ix) A brief description of the methods for assuring that recommended protective actions and distances are unambiguously communicated to response organizations.
(x) A brief description of any special instructions the licensee would give to fire, police, medical, and other emergency personnel.
(xi) A brief description of the means of restoring the facility to a O
v safe condition after an accident.
(xii) Provisions for conducting onsite drills at intervals not to exceed two years.
(3) The licensee shall allow the local government authorities expected to respond in case of an accident 60 days to comment on the licensee's emergency plan before submitting it to the NRC.
The licensee I
shall submit any comments received within the 60 days to the NRC with the I
PART 70 - DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL 6.
The authority citation for Part 70 is revised to read as follows:
AUTHORITY:
Secs. 51, 53, 161, 182, 183, 68 Stat. 929, 930, 948, 953, 954, j
as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2071, 2073, 2201, 1
l l
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2232, 2233, 2282); secs. 201, as amended. 202, 204, 206, 88 Stat. 1242, as amended, 1244, 1245, 1246 (42 U.S.C. 5841, 5842, 5845, 5846).
Section 70.7 also issued under Pub. L.95-601, sec. 10, 92 Stat. 2951 (42 U.S.C. 5851).
Section 70.21(g) also issued under sec. 122, 68 Stat.
939 (42 U.S.C. 2152).
Section 70.31 also issued under sec. 57d, Pub. L.93-377, 88 Stat. 475 (42 U.S.C. 2077).
Sections 70.36 and 70.44 also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.C. 2234). Section 70.61 also issued under secs. 186, 187, 68 Stat. 955 (42 d.S.C. 2236, 2237). Section 70.62 also issued under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138).
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.
2273); $$ 70.3, 70.19(c), 70.21(c), 70.22(a), (b), (d)-(k), 70.24(a) and (b), 70.32(a)(3), (5), (6), (d), and (1), 70.36, 70.39(b) and (c),
70.41(a), 70.42(a) and (c), 70.56, 70.57(b), (c), and (d), 70.58(a)-(g)(3),
and (h)-(j) are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C.
2201(b)); SS 70.7, 70.22a(a), and (d), 70.20b(c), and (e), 70.21(c).
70.24(b), 70.32(a)(6), (c), (d), (e) and (g), 70.36, 70.51(c)-(g), 70.56, 70.57(b) and (d), and 70.58(a)-(g)(3) and (h)-(j) are issued under sec. 1611, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and SS 70.20b(d) and (e), 70.38, 70.51 (h) and (1), 70.52,'70.53, 70.54, 70.55, 70.58(g)(4),
(k), and (1), 70.59 and 70.60(b) and (c) are issued under s'ec. 161o, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
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5 7.
In 5 70.22 paragraph (1) is revised to read as follows:
$ 70.22 Contents of applications.
(i)(1) Each licensee authorized to possess enriched uranium or plutonium in quantities such that a criticality accident alarm system is required, uranium hexafluoride in excess of 50 kg in a single container or 1000 kg total, or in excess of 2 curies of plutonium shall submit either:
(1) An evaluation showing that the maximum dose to a person a member of the public offsite due to a credible release of radioactive materials would not exceed 1 rem effective dose equivalent or an intake of 2 mg of soluble uranium, or (ii) an emergency plan for responding to a release of radioactive materials.
O V
(2) Each evaluation submitted under paragraph (i)(1)(1) of this section may include consideration of the following factors:
l (i) The radioactive material is physically separated so that only a portion could be involved in an accident.
(ii) All or part of the radioactive material is not subject to release during an accident or to criticality because of the way it is i
stored or packaged.
(iii)
In the case of fires or explosions, the release fraction would be lower than 0.001 due to the chemical or physical form of the material.
(iv) The solubility of the material released would reduce the dose received.
O 35
[7590-01]
(v) The facility design or engineered safety features in the facil-ity would reduce a release to lower values than those assumed in developing this section.
(vi) Operating restrictions or procedures would prevent a release large enough to cause a member of the public offsite to receive a dose exceeding i rem effective dose equivalent.
(vii) Other factors appropriate for the specific facility.
(3) Emergency plans submitted under paragraph (t)(1)(11) of this section must include the following information:
(1) A brief description of the facility and site area.
(ii) An identification of each type of accident for which protective actions for the public may be needed.
(iii) An analysis of the potential doses to the public or, for the case of uranium hexafluoride, exposures to toxic radioactive material, from each type of accident.
(iv)
Icentification of the means of detecting each type of accident in a timely manner.
(v) A brief description of the means and equipment for mitigating the consequences of each type of a.ccident, including those provided to protect workers onsite.
(vi) A brief description of the methods and equipment to assess releases of radioactive materials.
(vii) A brief description of the responsibilities of licensee personnel should an accident occur, including the identification of personnel responsible for notifying offsite authorities and notifying the NRC.
(viii) A brief description of the means of promptly notifying offsite authorities and of requesting offsite assistance resources.
36
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[7590-01]
(ix) A brief description of the methods for assuring that recommended protective actions and distances are unambiguously communicated to response organizations.
(x) A brief description of any special instructions the licensee would give to fire, police, medical, and other emergency personnel.
(xi) A brief description of the means of restoring the facility to a safe condition after an accident.
(xii) Provisions for conducting drills at intervals not to exceed two years.
(4) The licensee shall allow the offsite governmental authorities expected to respond in case of an accident 60 days to comment on the licensee's emergency plan before submitting it to NRC.
The licensee shall submit any comments received within the 60 days to the NRC with the emergency plan.
8.
In 5 70.23 paragraph (a)(11) is revised to read as follows:
Date at this _ day of
, 1985.
For the Nuclear Regulatory Commission.
4 l
t Samuel J. Chilk, Secretary of the Commission.
2 i
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