ML20153D745

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Requests Addl Info Re Util 871223 Proposed Rev 1, Gpu Nuclear Emergency Plan for TMI & Oyster Creek Nuclear Stations, Including Info on Figure 24 on Indefinite Delay for Protective Recommendation Given to Offsite Authorities
ML20153D745
Person / Time
Site: Oyster Creek, 05000000, Crane
Issue date: 05/03/1988
From: Ronald Bellamy
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Roche M
GENERAL PUBLIC UTILITIES CORP.
References
IEIN-83-28, NUDOCS 8805090273
Download: ML20153D745 (3)


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Docket Nos. 50-219 50-289 50-320 GPU Nuclear Corporation ATTN: Mr. M. B. Roche Vice-President and Director Quality and Radiological Control 1 Upper Pond Road Parsippany, New Jersey 07054 j

Gentlemen:

We have completed a pre-implementation review of proposed Revision 1 to the "GPU Nuclear Emergency Plan for Three Mile Island and Oyster Creek Nuclear Stations" (1000-PLN-1300-02), submitted under 10 CFR 50.54(q) on December 23, 1987. Our review indicates that the proposed changes do not reflect published j

NRC guidance regarding protective action recommendations, and further information is necessary from you regarding this matter in order for us to determine whether this revision may be implemented.

Figure 24 of your proposed plan indicates that an indefinite delay may follow declaration of a General Emergency before a protective action recommendation is i

given to offsite authorities. It is inconsistent to declare a General Emergency without issuance of a protective action recommendation. The definition of General Emergency states that, "... Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area." If these conditions do not exist, then a General Emergency should not be declared.

In the situation where your Emergency Action Levels require declaration of a General Emergency, but precise protective action recommendations have not been formulated, the guidance of NRC IE In-formation Notice 83-28 should be followed, i.e., as a minimum recommend sheltering to two miles 360 degrees and five miles downwind. This is especially important in the event of a fast-breaking accident in which your full emergency response organization has not been activated to assist in the decision-making process. This is also not inconsistent with upgrading to a subsecuent evacu-ation, as people will be indoors and alerted.

Figure 24 of the revised plan also appears to equate a "General Emergency" and "Potential for General Emergency" as the starting point for protective action decision-making. The emergency classifications are clearly defined in NUREG-0654.

The words, "Potential for a General Emergency Fxists", should be deleted from the first block of this figure.

The following additional comments are of lesser significance, but also should be corrected.

The evacuation time estimates noted in the implementing procedure should also be noted in the revised Figure 24, 1

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0 3 7939 Section 5.5 of Revision 1 to the Plan should be modified so the provisions of the Federal Radiological Emergency Response Plan (FRERP) are properly incorporated.

In addition, Section 5.5.1.2, as written, suggests an apparent mis-identification between the Federal Radiological Monitoring and Assessment Center (FRMAC) with FRERP.

The U. S. Department of Energy is the initial lead agency within FRMAC and all licensee requests for offrite federal assistance are coordinated by the U. S. Federal Emergency Management Agency (FEMA) via the NRC.

The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51.

Your cooperation with us in this matter is appreciated.

Sincerely, Nnat Sir,ntd Oy:

i., aid R. Guliomy Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch C C ',

P. B, Fiedler, Vice President and Director, Oyster Creek M. Laggart, BWR Licensing Manager, Oyster Creek Licensing Manager, Oyster Creek H. D. Hukill, Vice President and Director of TMI-1 T. G. Broughton, Operations and Maintenance Director, TMI-1 C. W. Smyth, Managar, TMI-1 Licensing R. J. McGoey, Manager, PWR Licensing, TMI-1 Ernest L. Blake, Jr.

Esquire TMI-1 Alert (TMIA)

Susquehanna Valley Alliance (SVA)

F. Standerfer, Director, TMI-2 T. F. Demmitt, Deputy Director, THI-2 R. E. Rogan, Licensing and Nuclear Safety Director, TMI-2 J. J. Byrne, Manager TMI-2 Licensing A. Miller, Manager, Plant Operations, THI-2 J. E. Frew, Defueling Director, TMI-2 J. B. Lieberman, Esquire F. Kantor, NRR W. Potts, TMI-2 Site Operations Director, TMI-2 Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Informatior. Center (NSIC)

NRC Resident Inspector State of New Jersey Commonwealth of Pennsylvania 0FFICIAL RECORD COPY EPTMI - 0002.0.0 03/18/88

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Region I Docket Room (with concurrences)

Management Assistant, DRPA DRP Section Chief Robert J. Bores, DRSS W. D. Travers, Director, TMI-2 Cler.nup Project Directorate J. Goldberg, OELD:HQ Gordon Edison, PM, NRR K. Abraham, PA0 Michael Masnik, PM, TMI-2 C. Amato, RI E. Fox, RI W/AiN

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