ML20128G324
| ML20128G324 | |
| Person / Time | |
|---|---|
| Issue date: | 05/10/1985 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Markey E, Simpson A, Udall M HOUSE OF REP., ENERGY & COMMERCE, HOUSE OF REP., INTERIOR & INSULAR AFFAIRS, SENATE, ENVIRONMENT & PUBLIC WORKS |
| References | |
| NUDOCS 8505300121 | |
| Download: ML20128G324 (17) | |
Text
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- . UNITED STATES h
j j NUCLEAR REGULATORY COMMISSION
"' 2 WASHINGTON, D.C.20555 '
OFFICE OF THE May 10, 1985 CHAIRMAN
-The Honorable Alan Simpson, Chairman
'Subcomittee on Nuclear Regulation Committee on Environment and Public Works United States Senate Washington,-D.C. 20510
Dear Mr. Chairman:
.The FY 1984-85 NRC Authorization Act stipulated that the Commission consider four issues in its efforts to upgrade its technical data acquisition capabili-ties for response to emergencies at licensed nuclear power plants:
"(A)_the appropriate role of the Commission during abnormal conditions at a nuclear reactor licensed by the Commission; (B) the information which should be available to the Comission to enable the Comission to fulfill such role and to carry out other related functions; (C) various alternative means of assuring that such information is available to the Commission in a timely manner; and (D) 'any changes in existing Comission authority necessary to enhance.the Comission response to abnormal conditions at a nuclear reactor licensed by the Comission."
The Commission has carefully considered and resolved each of these issues. The enclosed materials provide a description of these considerations and the conclu :
sions reached.
These materials are being provided to each of the Congressional committees with oversight responsibilities for NRC.
Sincerely, 1)'.
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. s B5053 850510 NRcc Nunzio J. Palladino PDR E PDR CORRESP Chairman
Enclosures:
Responses to Issues Delineated in
_FY 1964-85 NRC Authorization Act cc w/ enclosures:
Senator Gary Hart
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- r. 4 *4 UNITED STATES NUCLEAR REGULATORY COMMISSION f WASHINGTON. D.C. 20555
%...../ May 10, 1985.
OFFICE OF THE CHAIRMAN The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, D.C. 20515
Dear Mr. Chairman:
The FY 1984-85 NRC Authorization Act stipulated that the Commission consider four issues in its efforts to upgrade its technical data acquisition capabili-ties for response to emergencies at licensed nuclear power plants:
"(A) the appropriate role of the Commission during abnormal conditions at a nuclear reactor licensed by the Commission; (B) the information which should be available to the Commission to enable the Commission to fulfill such role and to carry out other related functions; (C) various alternative means of assuring that such information is available to the Commission in a timely manner; and (D) any changes in existing Commission authority necessary to enhance the Commission response to abnormal conditions at a nuclear reactor licensed by the Commission."
The Commission has carefully considered and resolved each of these issues. The enclosed materials provide a description of these considerations and the conclu-sions reached.
These materials are being provided to each of the Congressional committees with oversight responsibilities for NRC.
Sincerely,
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Nunzio J. Palladino I
Chairman l
Enclosures:
Responses to Issues Delineated in FY 1984-85 NRC Authorization Act i
i cc w/ enclosures:
Rep. Manuel Lujan
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' , 1 UNITED STATES
-8 S NUCLEAR REGULATORY COMMISSION f WASHINGTON D.C.20556 s,
/ May 10, 1985 CFFICE OF THE .
CHAIRMAN The Honorable' Edward J. Markey, Chairman Subcommittee on Energy Conservation and Power Committee on Energy and Commerce United States House of Representatives
. Washington, 0.C._
20515
Dear Mr. Chairman:
The FY 1984-85 NRC Authorization Act stipulated that the Commission consider four issues in its efforts to upgrade its technical data acquisition capabili-ties for response to emergencies at licensed nuclear power plants:
"(A)-the appropriate role of the Commission during abnormal conditions at a nuclear reactor.-licensed by the Commission;
-(B) -the information which should be available to the Commission to enable the Comission to fulfill such role and to carry out other related functions; (C) various alternative means of assuring that such information is available to the Commission in a timely manner; and (D) any changes in existing Comission authority necessary to enhance the Comission response to abnormal conditions at a nuclear reactor licensed by the Commission." i The Commission has carefully considered and' resolved each of these issues. The enclosed materials provide a description of these considerations and the conclu-sions reached. $ ,
These materials are being provided to each of the Congressional committees with oversight responsibilities for NRC.
Sincerely, jf.-i> $01 N u r~-
Nunzio J. Palladino Chairmaq
Enclosures:
l Responses to Issues Delineated in
'FY 1984-85 NRC Authorization Act cc w/ enclosures:
' Rep. Carlos Moorhead .
RESPONSES TO ISSUES DELINEATED IN FY 1984-85 NRC AUTHORIZATION ACT (A) "The appropriate role of the Commission during abnormal conditions at a nuclear reactor licensed by the Commission."
The revised role of this agency during a nuclear emergency has been defined in NUREG-0728, revised, which was forwarded to the Congress in February 1983. Briefly, the agency's role is fourfold. The NRC monitors the licensee to ensure that appropriate recommendations are being made
-with respect to offsite protective actions. The NRC informs other Federal agencies and entities and in coordination with other public affairs groups, informs the' news media of the NRC's knowledge of the situation.
The NRC provides advisory support-to the licensee and State and local authorities, including confirming the licensee's recommendations to offsite authorities. Finally, in some rare and unusual situations, the NRC may find it necessary to intervene by providing limited direction to the licensee.
The Commission believes that this role can best be fulfilled by sending a team of experts to the site of an emergency, with the Headquarters Operations Center providing the initial response during the 2 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> that the Site Team is in transit and providing support and analysis to the Site Team once it arrives.
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. (I B ) "The information which should be available.to the Commission to fulfill' such role and to carry out other related functions."
A list of parameters has been compiled and subjected to limited testing to evaluate -its value in enabling the Commission to fulfill its designated role. This data' set is designed to provide sufficient knowledge of (1) reactor coolant system conditions to assess the likelihood ~or extent of core damage, (2) containment building conditions to assess the likelihood of its failure, (3) radioactivity releases to assess the immediacy and
. degree of public danger, and (4) meteorological conditions to assess the
' distribution of. potential or actual impacts on the public. The lists of parameters.for Pressurized Water Reactors and Boiling Water Reactors are provided in Tables 1 and 2, respectively.
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(C) "Various alternative'means of' assuring that such information is available to the Commission-in a timely manner."
The Commission staff considered five options for acquiring this data.
.These were:
-1. A fully automated system for direct acquisition of data from plant sensors and transmission in standard format to NRC (this is a scaled down version of the Nuclear Data Link (NDL) concept, addressing only
-the new data list).
- 2. .A lice'nsee initiated transmission of selected parameters from exist-ing electronic data systems, which have been provided by_the licensees for their own emergency response facilities.
- 3. A computer terminal at each site for manual entry of manually ac-quired data that would be transmitted electronically to the Operations Center in a standard format.
- 4. A telefax system for transmitting image facsimile of manually com-piled data sheets.
- 5. An upgraded voice link, employing specially trained and qualified personnel as communicators.
Criteria for comparing these options were developed from problems encoun-tered during the agency's response to events and exercises and from previous criticism of the NOL concept. These criteria involve accuracy, reliability, timeliness, completeness, costs (in dollars and expert personnel), and backfitting requirements. These criteria have been more specifically delineated in Table 3. The five options have been compared against these criteria in Tables 4a through 4e, and the comparisons are summarized in Table 5.
On the basis of these considerations, the Commission staff has determined that the second option enumerated above provides the most appropriate means to support its emergency response role. Because of the emphasis on utilizing the electronic data systems already being developed by the licensees for their own emergency response facilities, this option has been named thn Emergency Response Data System (EROS).
Under the EROS concept, an electronic transmission system would be indi-vidually fashioned for each site. It would accept from the licensee's electronic information system (s), in the licensee's format, those parame-ters that are on the NRC's emcrgency data list. During declared emergen-cies, the ERDS would be activated by the licensee to begin transmissions to the Operations Center. Because the role performed by the licensees at their emergency response facilities (in particular their Emergency Operations Facilities, E0F) is similar to the role of the NRC during emergencies, the licensees' data systems already include most of the parameters desired by NRC. Those few parameters that are not included on a particular licensee's system can be communicated by voice over_the existing Emergency Notifica-tion System (ENS), thus avoiding requirements on that licensee to backfit the data system to include those parameters.
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With'the cooperation and assistance of the Duke Power Company, the ERDS concept was tested in a limited exercise during July 1984. Electronic data transmissions from the McGuire plant were provided by Duke's " Crisis Management Data Transmission System," utilizing a data list specifically restricted to parameters on NRC's emergency data list. This exercise-demonstrated that there is great value in using electronic data transmis-
.sion to obtcin a very modest set of reliable, time-tagged data at modest frequency. NRC's assessment activities were initiated sooner and pro-gressed more rapidly throughout the exercise. Data errors were eliminated.
The' Reactor Safety Team and the Protective Measures Team exhibited major. improvement in their abilities to focus on the significant factors and to predict the. course of the events relevant to protecting the_public.
. Questions addressed to the licensee were better focused, and'the burden on the licensee's telephone communicator was substantially reduced.
If the implementation of the ERDS concept makes a new regulatory requirement necessary then, prior to implementation of any new requirement, the concept would be developed further and made available for comment in
-accordance with NRC's rulemaking procedures.
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(D) 1"Any changes in existing Commission authority necessary to enhance the !
Commission response to abnormal conditions at a nuclear reactor licensed by the Commission."
The Commission does -not require any changes to its existing statutory authority in order to properly respond to abnormal conditions at licensed nuclear reactors. The role, as detailed in NUREG-0778, revised, is well within-the Commission's authorities under the Atomic Energy Act, as amended. The. Commission has authority under the Atomic Energy Act of 1954, as amended, to potentially direct all safety-related aspects of
. operation during an. emergency. .Under the existing regulatory framework, m licensees are primarily responsible for _ ensuring safe operation of their facilities. However, the Commission has the authority to order a-licensee during an_ emergency to take any number of possible protective actions,
- ranging from obtaining NRC concurrence before the licensee takes certain f actions to taking specific Commission-ordered actions to permitting actual operation of the facility by the Commission. The legal basis for ordering.
the licensee to take certain actions stems from Section 161 of the Atomic.
Energy Act, as amended (42 U.S.C. S 2201), which authorizes the Commission '
to issue orders governing the use of radioactive material and operation of nuclear facilities. Section 186c of the Atomic Energy Act, as amended
-(42 U.S.C. 8 2236(c)), authorizes the Commission "[i]n cases found by the v Commission to be of extreme importance... to the health and safety of the public" to " enter upon and operate the facility prior to any of the procedures provided under the Administrative Procedure Act."
=The reference to the Administrative Procedure Act in Section 186c is to the ' general rule applicable to all NRC . orders that, in ordinary circum-stances, the Commission is required to afford the licensee notice and an opportunity to be heard before the licensee is bound to take the ordered action. Notwithstanding the general requirement that a licensee be given a prior opportunity to be heard, the Commission has the authority to issue Lorders that are effective upon issuance to require a licensee to take certain actions-in circumstances compelling immediate action to protect public health and safety. See Administrative Procedure Act S 9(b),-
5 U.S.C S 558(c); 10 CFR 2.Y6Y(f) and 2.204. The use of immediately effec-
! tive orders must be justified by the emergency nature of the situation and by an overriding need to protect public health and safety by immediate action.
Notwithstanding this broad authority, the Commission has decided that its role during an emergency at a nuclear power plant should be limited to the functions discussed under Question A above. This role emphasizes'the licensee's responsibility-to operate its facility in a manner so as to protect the public health and safety, and it emphasized the NRC's respon-sibility to closely monitor the licensee's actions to assure that the public-health and safety is being protected to the best extent possible
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! g TABLE 1 PWR PARAMETER LIST Primary Coolant Pressure System Temperatures - hot leg Temperatures - cold leg Temperatures - core exit thermocouples
.Subcooling margin Pressurizer level RCS charging / makeup flow Reactor-vessel level (when available)
Reactor coolant flow
. Neutron flux - startup range
= Secondary Coolant Steam generator levels System Main feedwater flows- '
Auxiliary / Emergency feedwater flows
- Safety Injection High pressure safety injection flows Low pressure safety injection flows Safety injection flows-(Westinghouse)
Borated water storage tank level Containment Containment pressure Containment temperatures Hydrogen concentration Containment sump levels
- Radiation Monitoring i actor coolant radioactivity
. System Containment radiation level Condenser air removal radiation level Effluent radiation monitors '
Process radiation monitor levels
' Meteorological Wind speed Wind direction Atmospheric stability 6
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TABLE 2 BWR PARAMETER LIST Primary Coolant' Reactor pressure System Reactor vessel level Feedwater flow Neutron flux - startup range
-Safety Injection RCIC flow HPCI/HPCS flow Core spray flow LPCI flow Condensate storage tank level Containment Drywell pressure Drywell temperatures Hydrogen and oxygen concentration Drywell sump levels-Suppression pool temperature Suppression pool level Radiation Monitoring Reactor coolant radioactivity level System- Primary containment radiation level Condenser off gas radiation level Effluent radiation monitor Process radiation levels Meteorological Wind speed Wind direction Atmospheric stability i
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TABLE 3 CRITERIA FOR IMPROVING TECHNICAL DATA ACQUISITION Accuracy
-Minimize errors in acquiring data from plant sensors Minimize errors in transmitting data to Operations Center Reliability
-~ Availability for prompt implementation upon occurrence of an event Dependability of routine updating Timeliness.
Minimize delay initiating data transmission Minimize time elapsed between data acquisition and availability in Operations Center
' Completeness
-Obtain sufficient number of parameters Maintain associations of time and source among various data
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Cost Obtain favorable cost-benefit comparison with other alternatives Personnel Requirements Minimize number of technical experts needed to operate system Backfitting Requirements Minimize requirements on licensee and intrusion to plant systems 8
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TABLE 4a -
CONSIDERATIONS FOR FULLY AUTOMATED SYSTEM TAKING DATA FROM PLANT SENSORS
-(NUCLEAR DATA LINK)
Accuracy is excellent because there are no human interfaces.
Reliability is excellent because there are no human interfaces.
Timeliness is excellent because system is immediately available and capable of rapid transmission with frequent updating.
Completeness is potentially excellent because any necessary parameter can be accessed.
Cost is high because a totally new system must be developed for each plant.
No personnel are required for acquisition, transmission, or receipt of
. data.
Backfitting requirements would be extensive on licensees for equipment at plants.
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4 TABLE 4b CONSIDERATIONS FOR AUTOMATED SYSTEM ACCESSING LICENSEES' EXISTING ELECTRONIC DATA SYSTEMS (EMERGENCY RESPONSE DATA SYSTEM)
Accuracy is excellent because there are no human interfaces.
- Reliability is excellent because there are no human interfaces, and many systems such as Safety Parameter Display System (SPDS) will incorporate .
automatic data validation.
Timeliness is excellent because the system is immediately available and capable of rapid transmission with frequent updating. Promptness of initiation may vary depending upon licensees' system configurations. In some cases, activation may not occur until the licensee mans its technical support-center.
4m. .e Completeness is expected to be generally excellent because the primary objective of the SPDS requirement is to provide the licensee with a tool for quickly assessing the overall health of the plant; i.e., the same need that the NRC faces. It is expected that there would be minimal requests ,
for supplemental information to be transmitted by voice.
Cost is relatively low because most licensees are already installing systems to transmit data among their own Emergency Response Facilities (ERFs), but there will be substantial hardware and software interface requirements at the Operations Center to receive the diverse signals and formats.
No personnel are required for acquisition, transmission, or receipt of data on SPDS. Supplemental voice transmissions are not expected to overburden existing voice links.
Backfitting on plant systems would be minimal in that licensees only would have to provide one additional output port on the SPDS or other ERF data system.
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TABLE 4c CONSIDERATIONS FOR MANUAL DATA ACQUISITION AND TERMINAL ENTRY L -FOR ELECTRONIC TRANSMISSION
. Accuracy is poor because manual data acquisition and encoding is subject to instrument reading errors, handwriting reading errors, and typographi-cal errors.
Reliability is poor because manual data acquisition is easily interrupted.
Initiation would not be prompt because of personnel requirements.
Timeliness is only fair because acquisition and entry are time consuming,
-but data handling thereafter at NRC is automatic. Data verification could cause more extensive delays.
Completeness is potentially good, but acquisition time may limit number of parameters that can be handled.
Costs are modest, including at least a terminal and a modem for each reactor.
Personnel requirements include at least one person knowledgeable in plant operations to acquire data and one technical typist to enter data on a terminal. Verification of data would require at least one highly expert individual.
Backfitting of plant equipment would not be required.
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TABLE 4d CONSIDERATIONS FOR-A SYSTEM TO TELEFAX MANUALLY ACQUIRED DATA TO NRC
. Accuracy is poor because manual data acquisition and entry (at NRC) is Lsubject to instrument reading errors, handwriting reading errors, and
. typographical errors. Verification would be difficult because typist would not be-in room with plant personnel.
-~.ReliabilityLis poor because manual data acquisition is easily interrupted.
~ Initiation may not be prompt because of personnel requirements.
. Timeliness is only fair because acquisition and entry are time consuming, but data handling thereafter at NRC is automatic. Data verification would require return telefax and more delay.
- Completeness is potentially good, but acquisition time may limit number of parameters that can be handled.
Costs are modest, including a compatible telefax in each control room.
Personnel requirements include one person knowledgeable in reactor opera--
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tions to acquire data and one NRC employee to enter data.
Backfitting to plant. systems is not required.
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e TABLE 4e CONSIDERATIONS FOR A SYSTEM USING MANUAL ACQUISITION AND VOICE TRANSMISSION Reliability is poor because' manual data acquisition may be easily inter-rupted. Initiation would not be prompt because of personnel requirements.
Accuracy has been shown to be marginal for voice relay of data. Detection
-of instrument reading errors, handwriting reading errors, and typographical errors (at NRC) would depend on voice link readback for detection and correction. ,
Timeliness has been shown to be marginal because manual data acquisition and voice relay is too slow to transmit required data.
Completeness is poor because transmission time requirements seriously limit number of parameters that can be handled. Source and time reference have been demonstrated to be difficult to maintain with data relayed by voice.
Costs are not incurred unless additional telephone links are utilized to increase data transmission / verification rate.
Personnel requirements include an individual knowledgeable in plant operations to acquire data at the site and one technical typist to enter data at NRC. Additional telephone lines would require pairs of additional communicators.
Backfitting would not be required.
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' TABLE 5 COMPARISON OF OPTIONS ~
' EXPERT OPTIONS ACCURACY RELIABILITY TIMELINESS' COMPLETENESS COST PERSONNEL BACKFIT Nucle r Data Excellent Excellent Excellent Excellent High None Extensive.for Link Sensor Readouts 1 Emergency Response Excellent Excellent' Excellent
- Excellent Moderate None'- Minor for-0;ta System ~SPDS Output Manual Terminal Poor Poor' Fair But . Limited by Moderate Operations None At Site Not Prompt Time Specialist Telefax Poor Poor Fair But Limited by Moderate Operations None Not Prompt Time Specialist Qualified Voice Marginal Poor Marginal Limited by Hone Operations None Communicators Time Specialist 4
" Note: Activation time may vary depending upon licensees' equipment configurations. In some cases, activation may not occur until the licensee mans its Technical Support Center.
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