ML20137B188
| ML20137B188 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1997 |
| From: | Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| Shared Package | |
| ML20137B193 | List: |
| References | |
| NUDOCS 9703210206 | |
| Download: ML20137B188 (2) | |
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4% UNITED STATES g .
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, 4" NUCLEAR REGULATORY COMMISSION L WASHINGTON, D.C. 20666 0001 gg o -
% # Marchl19,1997 MEMORANDUM TO: Paul H. Lohaus, Deputy Director Office of State Programs FROM: Donald A. Cool, Director /
Division of Industrial and / l Medical Nuclear Safety, NMS(/ 'f
SUBJECT:
COMMENTS ON THE DRAFT EMERGENCY PLANNING REQUIREMENTS (PART P) FOR THE SUGGESTED STATE REGULATIONS We have reviewed your response to Conference of Radiation Control Program Directors conceming their draft emergency planning requirements and we concur subject to inclusion of the additional comments attached. We are available to discuss these comments if you have any questions.
Attachment:
As stated cc: F. Cameron, OGC B. Morris, RES CONTACT: Kevin Ramsey, IMNS g 415-7887 m
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_ IMNS COMMENTS ON THE DRAFT SUGGESTED STATE REGULATIONS, r PART P - PLANNING FOR LICENSEE RESPONSE TO CONTINGENCIES,
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DATED FEBRUARY 1997 .
Contact:
Kevin Ramsey 415-7887
- 1. Section P.5 should include a paragraph similar to 30.32(i)(2)(vii) stating that ;
the applicant may take into account other factors appropriate for the specific - y i facility that would prevent or reduce the dose to persons offsite.
i 2. Paragraph P.6(g)(i) requires that the plan contain names and titles. We -
{ suggest requiring titles only to minimize the need for formal plan revisions. /
- Names can be provided in the implementing procedures for the plan.
3 i 3. Section P 6(h) should include a requirement that the licensee commit to notify
- the Agency immediately after notification of appropriate offsite response
'7
- organizations and not later than one hour after the licensee declares an emergency. This is consistent with 30.32(i)(3)(viii). Paragraph P.11(b) should be revised to reflect this provision also.
I
<4. Paragraph P.6(h)(ii) refers to _"using offsite assistance on site." We suggest deleting the word "using" because it implies that the licensee will be directing ,
,' offsite agencies. In some cases such as fires, an official from the offsite
- agency (i.e., Fire Chief) may be in charge of the scene with the licensee j ;
l 4 providing technical support. We believe the reference to effective coordination 1 l of offsite assistance is sufficient. l 7 ,
- 5.' Paragraph P.6(h)(iii) should state that the arrangements with offsite agencies V
shall include the treatment of contaminated injured onsite workers. This is
- consistent with 30.32(i)(3)(viii).
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- 6. Paragraph P.6(j)(i) should require a description of the special instructions and 7 prientation tours that the applicant will offer to fire, police, medical, and other
, . emergency pe,rsonnel. Applicants are not required to provide training if the f'
g> 4 offsite.ageqcies decline the offer. )
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,7; - Paragraph P.6(k)(v) shoujd require t$at exercise scenarios are not known to
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inost exercise participants.' Some licensees have small staffs that make it very /
- difficult to exclude all participants from the planning process. This is consistent 5
with 30.32(i)(3)(xi,i)f a
- 8. ^ Sections P.9 and P.6(j) appear to be redundant. We suggest consolidating / l c - thsse sections.- 's "
i
- 9. Paragraph P.10(c) should slate that individuals critiquing exercises will not have direct implementation responsibility for the plan, not just the exercise. y Attachment i
Mr. Kcnnsth L. Waaver , ,
Environmental Protection Specialist IV Color do Departmtnt of Public Health and Environmsnt 4300 Cherry Creek Drive South Denver, CO 80222-1530
Dear Mr. Weaver:
We have reviewed the draft Part P, Planning for Licensee Response to Contingencies, emergency planning requirements you sent us for our review and comments. Our comments are as follows:
e The phrase "A commitment to and a brief description of the means to promptly notify the offsite response organizations..." is missing from P.6 h.
e In Part P, Appendix A, Quantities of Radioactive Materials Requiring Consideration of the Need for a Contingency Plan for Responding to a l Release: (a) the quantity of Californium-252 corresponding to 9 Ciis i 20 mg; (b) Germanium-68 needs to be on the list; (c) the listing for l lodine-124 should be for lodine-125; (d) Mercury-203 is listed twice while Molybdenum-99 has been omitted; (e) the GBq quantity for Sulfur-35 release is low by a factor of 10; (f) release fractions and Curie quantities are needed for Mixed Corrosion Products and Irradiated Material, Solid Noncombustible. l One small grammatical point, in P.7 " comments" should be plural such that the regulation t reads: "The licensee shall provide any commenta received within the 60 days to the l Agency with the contingency plan or amendment." l Besides these changes, we find the proposed regulations to be compatible with NRC regulations.
When the regulations are finalized, NRC will review the regulations for compatibility and concurrence per the procedure approved by the CRCPD. If you have any questions, please contact me at (301) 415-2320.
Sincerely, Kathleen N. Schneider Senior Health Physicist Office of State Programs Distribution:
SDroggitis PDR (YES V' NO )
DSollenberger CRCPD File DOCUMENT NAME: G:\LJR\ COREG. DOC *See previous concurrence.
Ts receive a copy of this document. Indicate in the box: "C' = Copy without attachment / enclosure *E* = Copy wrth attachment / enclosure *N* = No copy OFFICE OSP l OSP l OSP:DDl NMf5 ((j RES l OCG l OSP:D l NAME LRakavan:nb KSchneider PHLohaus -
DQlqll BMorris FCameron RLBangart ~
DATE 02/27/97* 02/28/97* 02/28/97* /03/((/97 03/ /97 03/ /97 03/ /97 OSP FILE CODE: SP-C-7
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l 1- Mr. Kenn:th L. Wcavsr -
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Environmtntal Protection Sp:cialist IV l
Col:rado Drpartm:nt of Public He11th cnd Environment '
4300 Cherry Creek Drive South /
. Denver, CO 80222 1530
Dear Mr. Weaver:
[
We have reviewed the draft Part P, Planningj'for Licensee Response to Contingencies, {
emergency planning requiremer'ts you sent bs for our review and comments. Our comments are as follows:
1 e The phrase "A commitment to and a brief description of the means to promptly notify the offsite response organizations..." is missing from P.6 h.
e in Part P, Appendix A, Quahtities of Radioactive Materials Requiring Consideration of the Needfor a Contingency Plan for Responding to a Release: (a) the quantity 9'f Californium-252 corresponding to 9 Ciis 20 mg; (b) Germanium-68/needs to be on the list; (c) the listing for lodine-124 should be for lodine-125; (d) Mercury-203 is listed twice while Molybdenum-99 has been omitted; (e) the GBq quantity for Sulfur-35 release is low b'y a factor of 10; (f) release fractions and Curie quantities are needed for Mixed Corrosion Products and Irradiated Material, Solid Noncombustible.
f I
One small grammatical point, in P.7 " comments" should be plural such that the regulation reads: "The licensee shall provide any comments received within the 60 days to the Agency with the contingency plan or amendment."
Besides these changes, we find the proposed regulations to be compatib!e with NRC regulations.
When the regulations are finalized,, NRC will review the regulations for compatibility and concurrence per the procedure app'oved by the CRCPD. If you have any questions, please contact me at (301) 415 2320.
Sincerely, Kathleen N. Schneider Senior Health Physicist Office of State Programs Distribution: '
/
SDroggitis PDR (YES v' NO )
DSollenberger CRCPD File DOCUMENT NAl/.E: G:\LJR\ COREG.D,0C 'See previous concurrence.
Ta receive a copy of this document, indicate in the boa: *C* = Copy without attachment / enclosure *E* = Copy with attachment / enclosure *N* = No copy OFFICE OSP l OSP OSP:D OSP:DDl NMSS l RES( $ OCG l NAME LRakavan:nb KSchneider / PHLohaus DCool BMorris /
FCameron RLBangart DATE 02/27/97' 02/28/97f 02/28/97* 03/ /97 03/j]/97 03/ /97 03/ /97 OSP FIL CODE: S P-C-7 I CNCf
. 3MPO
Mr. Kennsth L. Weavsr '
Environmental Protection Specialist IV l
Coloredo Department of Public Hsalth and Environment 4300 Cherry Creek Drive South Denver, CO 80222-1530 l
Dear Mr. Weaver:
We have reviewed the draft Part P, Planning for Licensee Response to Contingencies i emergency planning requirernents you sent us for ourp1 view and comments. Our comments are as follows: ,7 l
/
\
e The phrase "A commitment to and_ a brief description of the means to ;
promptly notify the offsite response organizations..." is missing from P.6h.
e In Part P, Append!x A Quantities ofhadioactive Materials Requiring Consideration of the Need for a Coritingency Plan for Responding to a Release: (a) the quantity of Califorliium-252 corresponding to 9 Ciis 20 mg; (b) Germanium-68 needs to be on the list;(c) the listing for lodine-124 should be for lodine-125; (d) Mercury-203 is listed twice while Molybdenum-99 has been omitted; (e) the GBq quantity for Sulfur-35 release is low by a factor of 10; (f) release fractions and Curie quantities are needed ,for Mixed Corrosion Products and Irradiated i Material, Solid Noncombustable.
^
h addition to these' addition,s/ alterations, visadvise th~aTyou add ddfinitions for terms such g
as "ev'ent", " incident", and " emergency."
One small grammatical point, in P.7 " comments" should be plural such that the regulation reads: "The licensee shall provide any comments received within the 60 days to the Agency with the contingency plan or amendment."
Besides these changes, we find the proposed regulations to be compatible with NRC regulations. 7 When the r gulations are finalized, NRC will review the regulations for compatibility and concurre,nce per the procedure approved by the CRCPD. If you have any questions, please contact 'me at (301) 415-2320.
Sincerely, Kathleen N. Schneider Senior Health Physicist Office of State Programs
/ Distribution:
RLeangart PDR (YES V NO )
PLohaus DSollenberger SDroggitis LRakavan KSchneider CRCPD File DOCUMENT NAME: G:\LJR\ COREG. DOC Tm nceive a copy of this document. Indicate in the boa: "C" = Copy without attachment /en kd " " = Copy with attachment / enclosure "N" - No copy OFFICE C)SP l OSP , ,l OSP$[Ql -
OCG l OSP:D l NAME LRak%ugab KSchneider O PHLohaud FCameron RLBangart DATE g /rz797 02/3fjt /97 02f([/97 02/ /97 02/ /97 OSP FILE CODE: SP-C-7
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EXECUTIVE TASK MANAGEMENT SYSTEM
<<< PRINT SCREEN UPDATE FORM >>>
TASK # - 7S-30 DATE- 02/11/97 MAIL CTRL. - 1997 TASK STARTED - 02/11/97
............ TASK DUE - 02/24/97 TASK COMPLETED -
/ / 1 TASK DESCRIPTION - PART P, PLANNING FOR LICENSEE RESPONSE TO CONTINGENCIES
..............." i (SUGGESTED STATE REGULATIONS FOR THE CONTROL OF RAD.) l REQUESTING OFF. - SR-1 REQUESTER - K. WEAVER WITS - 0 FYP - N PROG.- LJR PERSON -
STAFF LEAD - LJR PROG. AREA - I PROJECT STATUS - DUE TO K. WEAVER: 2/28/97 PLANNED ACC. -N /
LEVEL CODE -- 1 gghg (
,c (303) 692-3068 Fu (303)?59 5355 A* E-mail: kenneth.w eaver Wtate.co.us
' i.ts
- Web Site: httpl/www.statexo.udgov_dir/cdphe. dir/hm/
CArmiopat Kenneth L. Weaver ME Environmental Protection Specialist IV Uranium and Special Projects llealth Physics IIMWM RP B2 llazanlous Matenals and Waste Management Division GX) Ocrry Creek Dnve South Denver, Cularmki 80222-15 M l
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1 Suggested State Regulations - Group I of the Conference of Radiation Control Program Directors, Inc.
A Partnership Dedicated to Radiation Protection February 4,1997 .
Mem ers of a advisors to Conference of Radiation Control Program Directors (CRCPD) committees:
SR-1, Suggested State Regulations - Group i !
E-6, Emergency Response Planning E-26, Radioactive Material Transportation Enclosed is a DRAFT emergency planning requirements addition to the SuggestedState Regulationsfor the Control ofRadiation for your review and comment bck to me by February 28,1997.
This Part P, Planningfor Licensee Response to Contingencies, brings fonvard provisions for emergency j preparedness and response which originate in the April 7,1989 U.S. Nuclear Regulatory Commission )
10 CFR 30,40 and 70 regulations (54 FR 14051), a matter of compatibility, and also take cognizance of the 1905 NRC changes to 10 CFR 72 (60 FR 32430).
SR-1 recognizes that some states have incorporated these provisions in the basic licensing requirements (SSRCR Part C). We hope this Part P modular approach will focus development and improvement of these contingency planning requirements as well as fulfill the CRCPD Board charge to SR-1.
I Committee SR-I will first complete a Part P which conforms closely, as does the present draft, to the NRC approach with minor improvements. Later SR-1 will take up any major " matters for future consideration" 1
l've identified nine major areas of potential interest for comment, either now for polish or over time for major I longer term improvement: (1) alternative and additional definitions,(2) the threshhold dose (now 10 mSv) appropriate for administratively determining who is required to provide a contingency plan, (3) within the 10 mSv, how to provide for response, if any, to situations in which the annual individual dose limit of I mSv may be exceeded, or to explain why no response is needed (e.g. an accident doesn't occur every year),
(4) whether to include some requirements along a scale of response which includes incident or accident events ,
having only onsite involvement as distinct from events with clear potential offsite impact,(5) alternative or !
additional specifications for plan contents,(6) the appropriate frequency of drills and exercises, in particular the technical basis for these intervals,(7) which naturally occurring and accelerator produced radionclides to add to the Appendix,(8) whether, as broached by NRC's June 7,1985 ANPRM (50 FR 23960-23963), some demonstration of sufficient resources to pay for cleanup of accidental releases of ra* sctive materials is ]
needed, and (9) the best linkage and format in relation to Part C, Part T and other : ^ "R parts.
Please feel free to make either housekeeping-type comments or to suggest major aspects for future work.
Your comments will inform committee decisions on final draft language as well as explanations in the rationale document which will accompany a final draft Part P.
Thanks in advance for any help you can give. Please prodded your comments to me by February 28,1997.
). ;
Olt. (,l'd6N / l
/ i Office of the Committee Chairperson Kenneth L.K. Weaver Horordous Materials and Waste Monogement Division . Colorado Depodment of Public Health and Environment 4300 Cherry Creek Drive South (HMWM-RP-82) . Denver, Colorado 80222 1530 Telephone: 303/692-3068 . Fox: 303/759 5355.E-mail: kenneth weaver @ state.co.us
. l Ken Weaver Part P drafting notes, February 4.1997 1 l
Notes regarding wording choices in the initial draft Part P Section Comment General This draft was based upon existing NRC and State regulations.
General April 7,1989, 54 FR 14051, Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licenses (10 CFR parts 30, 40, and 70), in particular 10 CFR at 30.32(i),40.31(i),40.34(f) & 70.22(i). These provisions are a matter of compatibility.
General June 22,1995, 60 FR 32430-32442, Emergency Planning Licensing Requirements for independent Spent Fuel Storage Facilities (ISFSI) and Monitored Retrievable Storage Facilities (MRS),10 CFR Part 12, Final Rule i General State regulations from which initial wording was used for some provisions:
AK RH-403g, adopted 8/15/90 CO 3.9.11, effective 111/94 IL 330.500 Change based on wording innovations from other states is anticipated.
Title The title " Planning for Licensee Response to Contingencies" was chosen based on the May 1996 CRCPD Board suggestion that Part P title be " Licensing Contingency Planning". The term " contingency plan" was used throughout instead of " emergency plan".
P.3a The definition of " accident"is from the Intemational Basic Safety Standards.
Matter for Future Consideration: compare definition to IAEA International Nuclear Event Scale as definied in the INES users' Manual P.3a Other phrases that might be included in the definition of " accident" are:
" unauthorized release of radioactive material due to human error or negligence, system failure, an act of God, or defective components".
P.3b The definition of alert is that found in 10 CFR P.3c The definition of "offsite response organizations" is taken from wording in 60 FR 32430-32442 P.3d The definition of " protective action"is from 10 CFR and IL 330.50 P.3e The definition of " site" from CO radiation regulations Sec.1.4 P.3e The defintion of " site" includes the term " restricted area" which is defined in l Part A l
P.3f The definition of " site area emergency" is that found in 10 CFR & IL 330.50 )
P.3g The definition of " site boundary" from CO radiation regulations Sec.1.4 P.3 Matter for Future Consideration: include a definition of " event"?
i Hazardous Materials and Waste Management Division, Uranium & Special Projects Printed February 4,1997, 6:02 pm K. Weaver, C:\WV\J1\P\SRPK701 A.KW6
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Ken Weaver Part P drafting notes, February 4,1997 2 ;
Notes regarding wording choices in the initial draft Part P Section Comment P.3 Matter for Future Consideration: include a definition of " incident"? For example, based on IAEA, an event from which public exposuie is a fraction of prescribed limits.
P.3 Matter for Future Consideration: include a definition of " emergency"?
P.3 Matter for Future Consideration: include a definition of " general emergency"?
P.3 Matter for Future Consideration: include a definition of " emergency pla.in n zone"?
P.3 Matter for Future Consideration: include a definition of " drill"?
P.3 Matte, for Future Consideration: include a definition of " exercise"?
P.3 Matter for Future Consideration: include " serious incident" as requiring attention?
Per IAEA, a " serious incident" means a near accident from which public exposure ,
is a fraction of prescribed limits.
P.3 Matter for Future Consideration: include a definition of " protective measure",
used as different from " protective action" by some possession-only license holders to distinguish between onsite and offsite emergency preparedness needs l P.4a 10 mSv effective dose equivalent is used. This is used by the U.S. Nuclear Regulatory Commission as the administrative threshhold to determine whether a .
contingency plan is required, consistent with CO & IL. !
P.4a AK uses 5 mSv.
P.4a IAEA " incident"is 0.1 of TEDE limit for public, IAEA " accident"is at prescribed limit, the framework incorporated here is 10 times the 10 CFR 20 annual limit P.4a Matter for Future Consideration: ask the CRCPD Emergency Response Planning Committee E-6 to evaluate whether 1 mSv (100 mrem) is now more appropriate.
P.4a The word " maximum" was not included, since it adds no meaning to "not exceed".
P.4b nota bene "could be released" P.4 Since Appendix A, footnote 1, provides for combinations of materials,
" quantities"is used in P.4 and the title to Appendix A. Generally, a singular noun is preferred for clarity and precision, except when a plural is more appropriate. I P.4 Another approach would be to tabulate types of facilties for which contingency planning is required, e.g. major nuclear n'edicine/ broad medical licensecs (e.g.
10Ci l and l, in relation to reactors, ISFSI, MRS, ... (60 FR 32430 et seq.
mentions that " advanced reactor design" might not need an emergency plan) l Hazardous Materials and Waste Management Division, Uranium & Special Projects l Printed February 4,1997, 6:02 pm K. Weaver, C:\WV\J1\P\SRPK701 A.KW6 l I
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. Ken Weaver Part P drafting notes, February 4,1997 3 1
Notes regarding wording choices in .the initial draft Part P Section Comment P.4 Matter for Future Consideration: a smaller scale of contingency planning (strictly l onsite emergency planning) cou!d be required for the 1 mSv to 10 mSv range.
P.5 used language from IL:"may take into account whether" rather than NRC & AK:
l "One or more of the following factors may be used to support an evaluation submitted under this section."
P.5b used "because of the way it is stored or packaged." (AK) rather than "due to the I method of storage or packaging" (IL) l P.5d nota bene " predicted" P.5f added "or larger than" (IL)
P.5g Did not add a P.5g, "Other factors appropriate for the specific facility." as included by NRC, AK & CO but excluded by IL. Note that P.5e probably includes this flexibility. l P.6 used IL *shall" rather than AK "must" ,
P.6 note addition of "in sections having each page labelled with a data and revision number" to make explicit the accountable and dynamic nature of the contingency planning document P.6a Matter for Future ConiderMort whether to require delineation of an " emergency planning zone" of set raGus, fo, example 10 miles, or 1-5 miles as regarded appropriate for an ISFS!?
P.6b Matter for Future Consideration: insert " serious incident", with the IAEA INES j terminology in mind?
P.6b nota bene " involving radioactive material" ,
l P.6d Matter for Future Consideration: insert types of monitoring, e.g. visual, sniffers, area monitors,...?
P.6e Matter for Future Consideration: explicitly query whether respirators will be used? If sgwhether they're maintained and workers get medical exams, etc.
P.6f Matter for Future Consideration: explicitly query whether assessment estimates will be based on source term measurements or field airborne radioactivity detectors P.6g Matter for Future Consideration: explicitly query about role of site Radiation l Protection Officer?
P.6h.ii. From 60 FR 32441 l
Hazardous Materials and Waste Management Division, Uranium & Special Projects Printed February 4,1997, 6:02 pm K. Weaver, C:\WVU1\P\SRPK701 A.KW6 l
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Ken Weaver Part P draf ting notes, February 4,1997 4
- 1 I !
Notes regarding wording choices in the initial draft Part P l Section Comment l l
P.6).l. annual is the frequency for annual training (IL); AK asks for frequency to be i specified.
j P.6].iii. AK adds " thoroughly" l 1
P.6k.l. quarterly is the frequency of communication drills ]
P.6k.ii. semiannual is the frequency of radiological / health physics, medical and fire drills J
l P.6k.lii. biennialis the general rule for exercises, but that's not stated explicity in P.6k.iii., rather in P.10a.
60 FR 32433 diacusses whether amendments should also be subject to 60-day P.7 comment specification P.10a The general rule is biennial exercise; il requires annual exercise.
P.11 b "immediately" (IL). NRC and AK include "not later than one hour after the licensee declares an emergency.* 60 FR 32435: one commenter on ISFSI emergency response advocated 15 minutes.
P.13 licensee documentation and recordkeeping tie down P.xx Matter for Future Consideration: provision for taking possession of radioactive material in emergency?
App.A need to track down and make explicit the calculational basis for these values?
App.A note that NARM is covered by limits for "any other beta-gamma emitter", "any other alpha emitter" and other special cases App.A add the individual naturally occurring radionuclides listed by Bernie Bevill in 11/6/94 Attachment 3, in particular "'Ra, "Co, " Gallium, '"in, * ' Thallium App.A cross-comparison of App. A to Part D, Schedule B, would catch the additional radionuc! ides.
App.A Take up Terry Devine's offer (summary of Bevill-Weaver meeting October 1994) to comoile a more complete list of isotopes from Radiation Shielding Information Center to replace those of just AEA materials.
Reference NUREG-0654 Reference NUREG-1140: a standalone ISFSI is < 10mSv for any scenario, therefore contigency plan need have no formal offsite components.
Hazardous Materials and Waste Management Division, Uranium & Special Projects Printed February 4,1997, 6:08 pm K. Weaver, C:\WV\J1\P\SRPK701 A.KW6 l
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SSRCR Volume 1- DRAFT Part P, February 1997 PART P PLANNING FOR LICENSEE RESPONSE TO CONTINGENCIES P.1 - Purpose. This Part provides for preparedness and response to potentialincident or accident ev by specifying the content and exercise of a licensee contingency plan.
P.2 - Scope f
- a. Any person licensed to receive, possess, use, own, acquire, transfer or dispose radioactive materialis subject to this Part.
b.
In addition to conforming to the licensing requirements in Part C and the standards for protection in Part D, a licensee with forms and quantities specified in this Part is required to evaluate and be prepared to respond to a potential release of radioactive material.
P.3 - Definitions. As used in this Part, these terms have the defmitions set forth below.
a.
" Accident" means any unintended event (including an operating error, equipment failure or other mishap) the consequences or potential consequences of which cannot be ignored from view of protection or safety, b.
" Alert" means that an event may occur, is in progress, or has occurred that could lead to a release of radioactive material, but the release is not expected to require a response by efTsite response organizations to protect persons offsite.
- c. "OfTsite response organization" means the offsite organizations which may be needed to re to an emergency, for example, local fire, police, medical or other authorities.
d.
" Protective action" means an action taken by members of the public to protect themselves from radiation from an incident involving radioactive material, which may include sheltering, evacuation, relocation, control of access, administration of radioprotective drugs, decontamination of persons, decontamination ofland or property, or control of food or water.
e.
" Site" means the area within the site boundary, including the area upon which the licensee conducts activities and any restricted area.
- f. " Site area emergency" means that an event may occur, is in progress, or has occurred that co lead to a significant release of radioactive material and could require a response by offsite response organizations to protect persons offsite.
- g. " Site boundary" means that line beyond which the land or property is not owned, leased, or otherwise controlled by the licensee.
P1
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SSRCR Volume 1- DRAFTPart P. February 1997 P.4 - Dose Evaluation and Contingency Planning. Each application to possess radioact unsealed form, on a foil or plated source, or sealed in glass in excess of the quantities in Pa Appendix A, " Quantities of Radioactive Materials Requiring Consideration of the Need for a Contingency Plan for Responding to a Release", must contain either:
a.
An evaluation, as described in Section P.5, showing that the dose to a person offsite due to a release of radioactive material would not exceed 0.01 Sievert (I rem) effective dose equiv 0.05 Sievert (5 rems) to the thyroid; or b.
A contingency plan, as prescribed in Section P.6, for responding to any event in which radioactiv material could be released from the site.
P.5 - Evaluation of Potential Dose. In evaluating the total effective dose equivalent to an individual pursuant to subsection P.4a above, the applicant may take into account whether:
a.
The radioactive material is physically separated so that only a portion could be involved in an accident; b.
All or part of the radioactive material, because of the way it is stored or packaged, is not subject to release during an accident;
- c. The release fraction in the respirable size range is predicted to be lower than the release fraction shown in Part P, Appendix A, due to the chemical or physical form of the material;
- d. The solubility of the radioactive material is predicted to reduce the dose received;
- e. Facility design or engineered safety features in the facility are predicted to cause the release fraction to be lower than shown in Part P Appendix A;
- f. Operating restrictions or procedures are predicted to prevent a release fraction as large or larger than that shown in Part P, Appendix A.
P.6 - Contents of a Contingency Plan. A contingency plan for responding to a release of radioactive material submitted pursuant to Section P.4b above shall include the following information, in sections having each page labelled with a date and revision number:
- a. Facility description. A brief description of the applicant's facility and area near the site.
- b. Types oraccidents. An identification of each type of accident involving radioactive material for j
which actions may be needed to protect members of the public.
- c. Classification of accidents. A method for classifying each accident as an alert or site area j emergency as defined in P.3. l
- d. Detection of accidents. Identification of the means for detecting each type of accident in a timely manner.
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SSRCR Volume 1 - DRAFT Part P, February 1997
- e. Mitigation of consequences. A brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to protect workers onsite, and a description of the program for maintaining the equipment.
- f. Assessment of releases. A brief description of the methods and equipment to assess releases of radioactive material.
- g. Responsibilities.
- i. The names and titles of the applicant's personnel responsible for developing, maintaining and updating the plan.
ii. A brief description of the responsibilities of the applicant's personnel who will resporid if an accident were to occur, including identification of personnel responsible for promptly notifying offsite response organizations, including the Agency.
iii. A list of offsite response organizations and a description of their responsibilities and anticipated actions.
- h. Notification, coordination and use of offsite response organizations.
- i. A brief description of the means, in the event of an alert or a site area emergency, to promptly notify the offsite response organizations listed pursuant to subsection P.6g.iii.
above.
ii. A brief description of the arrangements made for requesting and efTectively coordinating and using offsite assistance on site, including provisions that exist for using other organizations capable of augmenting the planned onsite response.
iii. The assistance requested may include, but need not be limited to, medical treatment of contaminated or injured onsite workers.
iv. A description or drawing of designated locations from which control and assessment of an accident would be exercised (i.e., control points).
- v. Provisions for arranging notification and coordination so that unavailability of some personnel, parts of the facility, or some equipment will not prevent notification and coordination.
- i. Information to be communicated.
1
- i. A brief description of the information to be provided to offsite response organizations, I including the Agency, in the event of an alert or a site area emergency.
ii. The types ofinformation to be provided shall include the status of the facility, a ;
description of radioactive releases, the names and telephone numbers of onsite personnel l P3 l
1 SSRCR Volume 1 - DRAFT Part P. February 1997 designated as points of contact, and recommendations for actions, as necessary, to protect members of the public.
1 iii. A brief description of the types ofinformation to provided to the public.
1
- j. Training. I
- i. A brief description of the performance objectives and plans for annual training that the applicant will provide workers on how to respond to an emergency, including any special instructions and orientation tours that the applicant will provide for fire, police, medical )
and other emergency personnel.
l l
ii. Provisions for familiarizing personnel with site-specific emergency procedures.
iii. Provisions for thoroughly preparing site personnel for their responsibilities in the event of accident scenarios postulated as most probable for the specific site, including the use of drills, exercises and team training for such scenarios.
- k. Drills and exercises. Specifications for:
- i. Conducting quarterly communications checks with offsite response organizations that include the verification and updating of all necessary telephone numbers.
ii. Conducting semiannual radiological / health physics, medical and fire drills.
1 iii. Inviting offsite response organizations to participate in onsite exercises conducted i pursuant to subsection P.10 below.I' !
I iv. Using accident scenarios postulated as most probable for the specific site.
- v. Ensuring that accident scenarios are not known to exercise participants.
- l. Safe condition. A brief description of the means of restoring the facility to a safe condition afler an accident.
P.7 - Comment from OfTsite Response Organizations. Not less than 60 days prior to submittal of the contingency plan to the Agency, the applicant shall provide the contingency plan for cornment by offsite response organizations expected to respond in case of an accident. Amendments to the plan shall also be provided to offsite agencies for comment before submittal to the Agency. The licensee shall provide any comment received within the 60 days to the Agency with the contingency plan or amendment.
I
' Participation of offsite response organizations in exercises, although recommended, is not required.
P4
- p. .,.
SSRCR Volunw I- DRAFT Part P, February 1997 P.8 - Hazardous Chemicals. The applicant shall certify to the Agency that it has met its responsibilities under the Emergency Planning and Community Right-to-Know Act of 1986, Title III, Pub. L.99-499, if applicable to the applicant's activities at the proposed place of use of the radioactive material.
P.9 - Training. Each licensee required to submit a contingency plan pursuant to Section P.4bshall provide training at intervals not to exceed one year for each person who has a responsibility for responding to accidents postulated as most probable for the specific site.
P.10 - Conduct of Drills and Exercises. Each licensee required to submit a contingency plan pursuant to Section P.4bshall:
- a. Conduct cnsite exercises at intervals not to exceed two years to test the response to simulated
] emergencies;
- b. Perform critiques of drills and exercises and ensure that such critiques evaluate the
^ appropriateness of the contingency plan, emergency procedures, facilities, equipment, training of personnel, and overall effectiveness of the response; and
- c. Ensure that the critique of each exercise uses individuals not having direct implementation responsibility for conducting the exercise.
, d. Correct deficiencies noted in critiques of drills and exercises.
P.11 - Plan Implementation. Each licensee required to submit a contingency plan pursuant to Section P.4bshall:
- a. Comply with each provision and specitication of the contingency plan submitted to the Agency; and
- b. Notify offsite response organizations, including the Agency, immediately after the licensee declares an alert or site area emergency.#
P.12 - Plan Revision. Each licensee required to submit a contingency plan pursuant to Section P.4bshall, with each page labelled by revision date and number:
- a. Update the contingency plan at intervals not to exceed one year, and report the update to the Agency and to affected offsite response organizations within 30 days afler the update is completed; and
- b. Obtain Agency approval before implementing changes to the plan except for updates to names, titles and telephone numbers.
2 The reporting requirement of subsection P.1 lb above does not supersede or relieve a licensee from complying with the requirements of the Emergency Planning and Community Right-to-Know Act of 1986, Title Ill, Pub. L.99-499 or other State or federal reporting requirements.
P5
SSRCR Volunw I- DRAFT Part P, February 1997 P.13 - Documentation and Recordkeepint Each licensee required to submit a contingency plan pursuant to P.4bshall retain records of contingency plan training, exercises and revisions and records of all notifications and reports pursuant to P.12 or Part C of these regulations in accord with the recordkeeping requirements of Part C of these regulations.
Part P, Appendix A Quantities of Radioactive Materials Requiring Consideration of the Need for a Contingency Plan for Responding to a Release Release Ouantity Ouantity Radinactive11aterial' Eraction (GB11) (Ci) '
Actinium-228 0.001 148,000 4,000 Americium-241 0.001 74 2 Americium-242 0.001 74 2 Americium-243 0.001 74 2 Antimony-124 0.01 148,000 4,000 j Antimony-126 0.01 222,000 6,000 Barium-133 0.01 370,000 10,000 Barium-140 0.01 1,110,000 30,000 Bismuth-207 0.01 185,000 5,000 Bismuth-210 0.01 22,200 600 Cadmium-109 0.01 37,000 1,000 Cadmium-113 0.01 2,960 80 Calcium-45 0.01 740,000 20,000 Californium-252 0.001 333 9(2m)
Carbon-14 (Non-CO) 0.01 1,850,000 50,000 Cerium-141 0.01 370,000 10,000 ,
Cerium-144 0.01 11,100 300 Cesium-134 0.01 74,000 2,000 Cesium-137 0.01 111,000 3,000 Chlorine-36 0.5 3,700 100 Chromium-51 0.01 11,100,000 300,000 Cobalt-60 0.001 185,000 5,000 Copper-64 0.01 7,400,000 200,000 Curium-242 0.001 2,220 60 Curium-243 0.001 110 3 Curium-244 0.001 148 4 Curium-245 0.001 74 2 Europium-152 0.01 18,500 500 Europium-154 0.01 14,800 400 Europium-155 0.01 111,000 3,000 Gadolinium-153 0.01 185,000 5,000 Gold-198 0.01 1,i10,000 30,000 P6
-- . .. ~
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SSRCR %dume !- DRAFT Part P. February 1997 i
Ouantity Release Ouantity i
RadioactivtMatetial Fraction (GBq) (Ci)
Hafnium-172 0.01 14,800 400 l Hafnium-181 0.01 259,000 7,000
, Holmium-166m 0.01 3,700 100 Hydrogen-3 0.5 740,000 20,000 Indium-114m 0.01 37,000 1,000 ,
Iodine-124 0.5 370 10 l lodine-131 0.5 370 10 Iridium-192 0.001 1,480,000 40,000 Iron-55 0.01 1,480,000 40,000 l Iron-59 0.01 259,000 7,000 !
Krypton-85 1.0 222,000,000 6,000,000 Lead-210 l
0.01 296 8 Manganese-56 0.01 2,220,000 60,000 Mercury-203 0.01 370,000 10,000 j Mercury-203 0.01 1,110,000 30,000 Neptunium-237 0.001 74 2 l Nickel-63 0.01 740,000 20,000 1 Niobium-94 0.01 11,100 300
- Phosphorus-32 0.5 3,700 100 Phosphorus-33 0.5 37,000 1,000 Polonium-210 0.01 370 10 Potassium-42 0.01 333,000 9,000 Promethium-145 0.01 148,000 4,000 Promethium-147 0.01 148,000 4,000 Ruthenium-106 0.01 7,400 200 Samarium-151 0.01 148,000 4,000 Scandium-46 0.01 111,000 3,000 l Selenium-75 0.01 370,000 10,000
)
! Silver-110m 0.01 37,000 1,000 l Sodium-22 0.01 333,000 9,000 l Sodium-24 0.01 370,000 10,000 Strontium-89 0.01 111,000 3,000 1 Strontium-90 0.01 3,330 90 Sulfur-35 0.5 33,30 900 Technetium-99 0.01 370,000 10,000 Technetium-99m 0.01 14,800,000 400,000 ,
Tellurium-127m 0.01 185,000 5,000 4 Tellurium-129m 0.01 185,000 5,000 Terbium-160 0.01 148,000 4,000 Thulium-170 0.01 148,000 4,000 Tin-113 0.01 370,000 10,000 Tin-123 0.01 111,000 3,000 ,
P7
- . . *' . ./
SSRCR Volume 1 - DRMT Part P, February 1997 Release Ouantity Ouantity Radioactlyc11aterial' Eraction (GRq) (Ci)
Tin-126 0.01 37,000 1,000 Titanium-44 0.01 3,700 100 Vanadium-48 0.01 259,000 7,000 Xenon-133 1.0 33,300,000 900,000
- Yttrium-91 0.01 74,000 2,000 Zinc-65 0.01 185,000 5,000 Zirconium-93 0.01 14,800 400 Zirconium-95 0.01 185,000 .5,000 Any other beta-gamma emitter 0.01 370,000 10,000 Mixed fission products 0.01 37,000 1,000 Contaminated equipment, beta-gamma 0.001 370,000 10,000 Irradiated material, any form other than solid noncombustible 0.01 37,000 1,000 Mixed radioactive waste, beta-gamma 0.01 37,000 1,000 Packaged mixed waste,2 beta-gamma 0.001 370,000 10,000 Any other alpha emitter 0.001 74 2 Contaminated equipment, alpha 0.0001 740 20 2
Packaged waste, alpha 0.0001 740 20
' For combinations of radioactive materials, the licensee is required to consider whether a contingency plan is needed if the sum of the ratios of the quantity ofeach radioactive material authorized to the quantity listed for that material above exceeds one.
2 Waste packaged in Type B containers does not require a contingency plan.
P8
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. q' General description of Ihe scale e Although the same scale is used for allinstallahons, it is physically impossible for events to occur which involve lhe release to the environment of considerable quantities of radioactive material at some types of installa-The international Nuclear Event Scale ilNES) is a tool lo promptly hon For these installations. the upper levels of the scale would not be and consistently communicale to the pubbc 1he safety significance of applicaole. These include research reactors. unieradiated nuclear fuel reported events at nuclear installa00ns. By putting events into proper per- treatment facilities, and waste storage sites spective, the Scale can ease comtnon understanding among the nuclear e indusirial accidents or other events which are not related to nuclear community, the media, and the pubhc 11 was designed by an international or radiologrcal operations are not classified and are termed "out of scale" group of experts convened Jomtly by the international Atomic Energy For example, although events associated with a turbine or generator can Agency (IACA) and the Nuclear Energy Agency (NEA) of the Organ:sation affect safety related equipment. faults affecimg only the availability of a for Economic Co operation and Development The group was guided m its turbine or generator would be classified as out of scale. Similarly, events work by the findings of a series of mternational meetings held to discuss such as fir 65 are to be considered out of scale when they do not involve general pnnciples underlying such a scale The Scale also reflects the any possible radiological hazard and do not affect the safety layers.
expenence gamed from the use of similar scales in France and Japan as well as from considerahon of possible scales m several other Countries. e The Scale is not appropnate as the basis for selecting events for feedback of operational experience, as important lessons can often be initially applied for a trial penod to classify events at riuclear power learnt from events of relatively minor significance.
plants,32 countnes participated in the trial and international agencies and user countries monitored progress. The Scale operated successfully and e it is not appropnate to use the Scale to compare safety performance now has been made avadable for formal adoption by each Country. The among countries Each country has different arrangements for reporting Scale also has been extended and adapted to enable it to be applied to all minor events to the public, and it is difficult to ensure precise international nuclear installations associated with the civil nuclear industry and to any consistency in rating events at the boundary between level 0 and level 1.
events occurring dunng the transport of radioactive matenals to and from The statistically small number of such events, with variability from year to those facihties. year, makes it difficult to provide meaningful international compansons.
Events are classified on the Scale at seven levels. Their desenptors e Although broadly comparable, nuclear and radiological safety and enteria are shown opposite with examples of the classification of enteria and the terminology used to desenbe them vary from country to nuclear events which have occurred in the past at nuclear installations. The country. The INES has been designed to take account of this fact.
lower levels (1-3) are termed incidents, and the upper levels (4-7) acci-dents. Events which have no safety significance are classified as level 0/
below scale and are termed deviations. Events which have no safety relevance are termed out of scale The structure of the Scale es shown opposite,in the form of a matrix with key words. The words used are not intended to be precise or defmitive Each enterion is defmed in detail within an INES Users' Manual Events Examples of classified nuclear events are considered in terms of three safety attnbutes or cnteria represented by each of the columns: off-site impact, on-site impact, and defence in depth degradation.
e The 1986 accident at the Chernobyl nuclear power plant in the The second column in the matnx relates to events resulting in off- S viet Union (now in the Ukraine) had widespread environmental and site releases of radioactivity. Since this is the only consequence havmg a human health effects. It is thus classified as Level 7.
direct effect on the publ c, such releases are understandably of particular
- W concern. Thus, the lowest pomt in this column represents a release giving e The 1957 accident at the Kyshlym reprocessir'g plant in the Soviet (ni Union (now in Russea) led to a large off-site release. Emergency measures the most exposed person off-site an estsmated radiation dose numer'cally including evacuaton of the population were taken to limit sencus health equivalent to about one-tenth of the annual dose hmst for the pubhc; this is effects. Based on the off-site impact of this event it is classified as Level 6.
classified as level 3. Such a dose is also typically about one-tenth of the average annual dose received from natural background radiation. The e The 1957 accident at the air-cooled graphite reactor pile at highest level is a major nuclear accident with widespread health and Windscale (now Sellafield) facility m the United Kingdom involved an environmental consequences g ,
impact, it is classified as Level 5 The third column considers the on-site impact of the event. This category covers a range from level 2 (contaminaton and/or overexposure e The 1979 accident at Three Mile Island in the United States resulted of a worker) to level 5 (severe plant damage such as a core mett). in a severely damaged reactor core The off-site release of radioactivity was All nuclear facihties are designed so that a succession of safety ,
layers act to prevent major on-site or off-site impact and the extent of the safety layers provided generally will be commensurate with the potential for United Kmgdom (now Sel!afseld) mvolved a release of radioactive material on and off site impact, These safety layers must all fa:4 before substantial , g ott site or on-site consequences occur. The provision of these safety layers gg g is termed "deience in depth", The tourth column of the matrix relates to incidents at nuclear insta!1ations or dunng the 1,ansportation of radioactive e The 1980 accident at the Saint-Laurent nuclear power plant in France resulted m partial damage to the reactor core, but there was no matenals m which these detence in depth provisions have been degraded. external release of radioactivity. It is classihed as Level 4, based on the This column spans the incident levels t-3 on-site irroact An event which has characteristscs represenied by more than one e The 1983 accident at the RA-2 cntical assembly in Buenos Aires,
' cnterion is always classified at the highest level accordmg to any one cntenon. Argentina, an accidental power excursion due to nonobservance of safety tules during a core modification sequence, resulted in the death of the operator, who was probably 3 or 4 metres away. Assessments of the doses absorbed by the victim indicate 21 Gy for the gamma dose together with 22 Gy for the neutron dose. The event is classified as Level 4, based on the on-site impact.
( e The 1989 incident at the Vanderlos nuclear power plant in Spain did i Using the Scale not result in an external release of radioactivity, nor was there damage to the reactor core or contamination on site However, the damage to the plant's safety systems due to fire degraded the defence-in4epth signifi.
e Although the Scale is designed for prompt use followmg an event. cantly. The event is classified as Level 3, based on the defence in-depth cnterion.
there will be occasions when a longer time-scale is required to understand and rate the consequences of an event. In these rare circumstances, a e The vast majonty of reported events are found to be below Level 3 provisional ratmg w'll be given with conf #rmahon at a later date. It is also Although no examples of these evenis are given here, countnes usmg the possible that as a result of further information, an event may require Scale may mdividually wish to provido examples of events at these lower reclassification. levels.
e If a radiological emergency were to occur in the vicmity of a nuclear instatlation or during the transport of radioactive matenals, existing national emergency planning arrangements would be 6mplemented The Scale should not be used as part of the formal emergency arrangements
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in%eq ' l T*9 OFF-SITE RISK 1 lent to the order of hundreds tofthousands t uneliM e-1 *IT 5 i A. - , Q,c 3', 9 3M's ei Such a release would, bejikely)" esult m in Q ia!{l@pleEeEtati Y4u)nt ' I -} F ft u y e V73 9Mi w measures covered.by emer ans to lessen theililMli eht
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- External release of radioactivity resulting in a dose to the most exposed WITHOUT individual off-site of the order of a few milisieverts.* With such a release the SIGNIFICANT need for off-site protective actions would be ger.erally unlikely except possibly OFF-SITE RISK for local food control.
Windscale e Significant damage to it e nuclear facility. Such an accident rnight include - Reprucessing damage to nuclear plant leading to major on-site recovery problems such as - Plant, UK,1973 partial core melt in a power reactor and comparable events at non4eactor- Saint Laurent NPP,
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I INCIDENTS SERIOUS INCIDENT
- External release of radioactivity above authorised limits, resulting in a dose <
3 to the most exposed individual off site of the order of tenths of millisievert.' I With such a releast, off-site protective measures may not be needed. l e On site events resulting in doses to workers sufficient to cause acute l' health effects and/or an event resulting in a severe spread of contamination for example a few thousand terabecquerels of activity released in a secondary containment where the material can be returned to a satisfactory storage area.
e incidents in which a further failure of safety systems could lead to accident Vandellos NPP, conditions, or a srfuation in which safety systems would be unable to prevent Spain,1989 ,
an accident if certain initiators were to occur.
l 2 INCIDENT . e incidents with significant failure in safety provisions but with sufficient i defence in depth remaining to cope with additional failures. I e An event resulting in a dose to a worker exceeding a statutory annual dose limit and/or an event which leads to the presence of significant quanti-ties of radioactivity in the installation in areas not expected by design and which require corrective action.
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