ML20203N150
| ML20203N150 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, 05000000 |
| Issue date: | 01/27/1986 |
| From: | Cunningham G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20198G688 | List:
|
| References | |
| NUDOCS 8609230169 | |
| Download: ML20203N150 (1) | |
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Note.to: Harold R. Denton, Director Office of Nuclear Reactor Regulation From:
Guy H. Cunningham, III Executive Legal Director
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SUBJECT:
CALVERT CLIFFS EPZ In my memorandum to you dated December 31, 1985, I advised you that OELD has concluded that there are no hearing rights associated with the denial of an exemption request. I note that BG&E now has also requested a license amend-ment in connection with its exemption request to reduce the Calvert Cliffs EPZ.
If BG&E does not voluntarily withdraw its application for a license amendment and the Staff subsequently denies the amendment application, then BG&E would have a right, pursuant to section 189 of the Atomic Energy Act and 10 C.F.R..62.108, to request a hearing on the denial of its license amendment application, o
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Guy W. Cunningham, [
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UNITED STATES
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FE0 4 1955 Docket Nos. 50-317 and 50-318 Mr. J. A. Tiernan Vice President - Nuclear Energy Baltimore Gas & Electric Company P. O. Box 1475 Baltimore, Maryland 21203 QearMr.Tiernan:
We have considered your November 18, 1985 and January 10, 1986 applications concerning the reduction in the emergency planning zone (EPZ) at Calvert
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Cliffs. The applications request an exemption from the requirements of 10 CFR 50.47(c)(2) and Section I of 10 CFR Part 50, Appendix E, that the EPZ be established at a distance of generally 10 miles.
You have proposed an EPZ of 2 miles. We have noted that your applications rely heavily on technical information relating to severe accident issues which are still under review bf industry and the NRC staff.
As you know, we have been working with the industry group IDCOR on the issues of severe accidents and source terms and even though numerous technical issues have been resolved, others remain to be resolved.
Also, the staff is presently evaluating.the numerous comments received on the draft report NUREG-0956,
" Reassessment of the Technical Bases for Estimating Source Terms." The extent o' +,he technical questions raised in these comments would need considerable erint before NUREG-0956 is published in final form. The ACRS comments dated December 12, 1985 on the adequacy of the present information is enclosed for your information. We are also establishing an interface between the NRC staff and the Atomic Industrial Forum (AIF) to provide a forum for industry input as well as technical exchanges on source term related issues. The NRC staff will use the insights gained from all of these activities to develop options on a number of source term related issues, including your prcposal to modify the emergency planning requirements.
Based upon the above, we believe your applications dated November 18, 1985 and January 10, 1986 for reduction in the EPZ are premature.
Therefore, based upon the information supplised in support of your exemption requests, we plan to defer action on these issues until the draft NRC findings you cite upon have become final.
Sincerely,
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Harold R. Denton, Director g
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t Mr. J. A. Tiernan Baltimore Gas & Electric Company Calvert Cliffs Nuclear Power Plant cc:Mr. William T. Bowen, President Regional Administratpr Region I Calvert County Board of U.S. Nuclear Regulatory Commission Commissioners Office.of Executive Director Prince Frederick, Maryland 20768 for Operations 631 Park Avenue
.D. A. Brune, Esq.
King of Prussia, Pennys1vania 19406 General Counsel Baltimore Gas and Electric Company Mr. W. J. Lippold, Manager P. O. Box 1475 Nuclear Engineering Services Baltimore, Maryland 21203 Calvert Cliffs Nuclear Power Plant MD Rts 2 & 4, P. O. Box 1535 George F. Trowbridge, Esq.
Lusby, Maryland 20657-0073 Shaw, Pittman, Potts and Trowbridge 1800 M Street, NW Mr. M. E. Bowman, General Supervisor Washington, DC 20036 Technical Services Engineering Calvert Cliffs Nuclear Power Plant Mr. J. R. Lemons MD Rts 2 & 4, P. O. Box 1535 Manager Nuclear Operations Lusby, Maryland 20657-0073 Baltimore Gas and Electric Company Calvert Cliffs Mr. R. M. Douglass, Manager MD Rts 2 & 4 Quality Assurance & Support Services Post Office Box 1535 Baltimore Gas and Electric Company Lusby, Maryland 20657-0073 Calvert Cliffs Nuclear Power Plant P. O. Box 1535 Lusby, Maryland 20657-0073 Resident Inspector c/o U.S. Nuclear Regulatory Commission Combustion Engineering, Inc.
P. O. Box 437 ATTN: Mr. R. R. Mills, Manager L.usby, Maryland 20657-0073 Engineering Services P. O. Box 500 Mr. Leon B. Russell Windsor, Connecticut 06095 Manager - Nuclear Maintenance Calvert Cliffs Nuclear Power Plant Department of Natural Resources MD Rts 2 and 4 P. O. Box 1535 Energy Administration, Power Plant Lusby, Maryland 20657-0073 Siting Program ATTN: Mr. T. Magette Bechtel Power Corporation Tawes State Office Building ATTN: Mr. D. E. Stewart Annapolis, Maryland 21204 Calvert Cliffs Project Engineer 15740 Shady Grove Road l
Gaithersburg, Maryland 20760 l
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S ALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475
- BALTIMORE, MARYLAND 21203 JOSEPH A.TsERNAN VICE PngssOENT NucLtan Entnow I
March 27,1936 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
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Washington, D.C. 20555 ATTENTION:
Mr. Harold R. Denton, Director
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. I and 2; Docket Nos. 50-317 & 50-313 Reduction of the Emergency Planning Zone
REFERENCES:
(a)
Letter from 3. A. Tiernan, (BC&E), to E. 3. Butcher, Jr., (NRC),
Request for Exemption, dated November 13,1935 (b)
Letter from 3. A. Tiernan, (BC&E), to Mr. A. C. Thadani, (NRC),
Request for License Amendment, dated January 10,1936 Gentlemen:
Thank you for your letter dated February 14, 1936, responding to our application for reducing the size of the Calvert Cliffs plume exposure emergency planning zone. We concur that it is reasonable to defer a review of our application until public comments have been resolved on those portions of NUREG-0956 referenced in our analysis. In this regard, we would be pleased to meet at your convenience to discuss your schedule for commencing a review.
In your letter you characterized the staff's ongoing efforts with the IDCOR group and a rewly-established interface with the Atomic Industrial Forum (AIF) as activities which are expected to provide additional inputs to a review. Whereas we commend the staff for engaging in these important activities, we do not feel that they pertain directly to our application. As you know, we are a member of IDCOR and AIF and have been an active participant in both of the activities to which you refer. The objectives of these activities are to develop a generic methodology for implementation of the NRC's severe accident policy and to determine how updated source terms can be incorporated into regulatory practice through generic ru!cmaking and revisions to regulatory guidance.
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. Mr.' H. R. Denton March 27,1936
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In contrast, our application involves a plant-specific request for exemption from = an ex! sting rule, justified by a showing that the underlying purpose of that rule would continue. to be served if-the exemption were to be granted. No cht.nges would be required to the subject rule (10 CFR 50.47), to the basis for this rule (NUREG-0396), or to any associated regulatory guidance. Thus, we believe that our request should be held separate and distinct from any longer-term, generic activities.
If you should have any questions, please do not hesitate to contact us.
Very truly yours, f.
l&V.4(.AA JAT/BSM/dmk cc:
D. A. Brune, Esquire
- 3. E. Silberg, Esquire T. Magette, DNR D. H. Jaffe, NRC
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T. Foley, NRC
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t BALTIMORE GAS AND ELECTRIC CHARLES CENTER. P.O. 80Z 1475. BALTIMORE, MARYLAND 21203 April 1, 1986 NUCLEAR OPERATIONS DEPARTMENT CALvtaf CUFfb NUCLEAR PowtR PLANT LU$SY, WAAfLAND 20657 The attached technical memorandum was prepared by Mr. Thomas Magette, Administrator, Power Plant Siting Program, Maryland Department of Natural
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Resources. It presents a perspective on Baltimore Gas and Electric Company's request for the Calvert Cliffs Emergency Planning Zone reduction.
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Supervisor'-Erjeigency Planning Attachment TEF/ bee i-a
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s C2I,VERP C[.IFFS DERGDCY HRNDG 2CNE RSXJCTICN he Baltimore Gas and Electric Cor::pany has asked the Nuclear Regulatory Ccemission (tGC) to reduce the plume exposure pathway Dnergency Planning Zone (EPZ) at its Calvert Cliffs ibclear Power Plant from 10 miles to 2 miles.
Specifically, BG&E has requested an exerption frcn the requirement of 10 CFR 50.47 (c) (2) and Ippendix E of that part that the EP2 consist of an area of about 10 miles in radius.
This technical remorandum describes the technical basis for the existing plume expsure patnway radius of 10 miles, the technical basis for BG&E's requested exe::ption, the process under which this request will be reviewed, the roles that various state agencies play in emergency planning, and 1
the pratical effects that might result in the event BG&E's request is granted.
TECHNICAL BASIS PCR E:CISTDC DERGDCf PIREDG L%S
'Ihe concept of an Emrgency Planning Zone was developed by a joint NRC and Environmental Protection Agency (EPA) Task Force on Emergency Planning and.
described in their Dece:toer 1978 report, Planninc Pasis for the Develec~ent of S* ate and Incal Govern ~ent Radiolecical Emercency ResDonse Plans in Su wrt of Licht Water Nuclear Mwer Plants (1).
':he Task Force described EP2s as "...
the areas for whicn planning is recc::Inended to assure that prcx::pt and effective actions can be taken to protect the public in the event of an accident."
Tne plume expsure pathway EPZ is designed to protect the public frca direct exp sure by airborne radioactivity.1 The appropriate radius for the plume exposure pathway. EPZ was determined by evaluating the potential radiation dose to a re:::cer of the general public resulting frce a range of itvpothetical accidents.
Tne quantity of radicactivity released for that range of accidents and the meteorological conditions at the ti:te of the accident determine the potential radiation cbse.
Eacn of these fac ors, and their significance in establishing tne.m2, discussed below.
are Radiation Doso Doses, or projec ed doses, whica require some action to protect public from threatening radiation cbses are known as Protective Action Guides tne (PAGs).
PAGs have been estaclished by EPA to provide scme standari:ed critern for initiating protective ac. ions (2).
Protective actions may include sucn measures as evacuation or sneltering.
As shown in Table 1, tne PAGs for the general population are presented as ranges.
'Ihe lower ranges should be used unless there are site specific i pediments to providing protection at level.
values should not ce exceeded in any case.Khile local constrain:s may make lo tna:
l mergency planning regulations also require plan: ting for a 50-mile E
Ingestion Expsure Pathway EP2 which is designed to protect radius radioactivity conta::dnated fcod and wa:er.
the punlic frcm
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Projected Dose (rem) tyroid 1-5 Whole Body 5-25 Table 1.
Protective Action Guides for General-Public for Plume Exposure Pathway.
Range of W i % ts i
In determining an appropriate size for the plume egosure pathway EPZ, the joint Task Force did not identify a specific accident. sequence upon which planning should be based.
"Rr.ther, it identified the bounds of the parameters l
for which planning is re==3 ed, - based upon knowledge of the potential d
consequences, timing, and release characteristics of a spectrum of accidents"
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(3).
Se spectrum of accidents include design casis accidents and the more severe Class 9 accidents.
Se design basis accident (DBA) is.a hypothetical accident' of very low probability with potential for very large radioactive releases.
2e mncept of the DBA was developed specifically to address nuclear power plant licensing considerations.
Se consequences of a DBA are evaluated in deterraning site suitability and performance standards of engineered. safety features.
4 S e nost severe DBA is typically the design basis loss-of-coolant accident (DBA-LOCA).
Although this accident scenario is not considered realistic, and the radioactive releases are more severe than those realistically expected, the DBA-IOCA is typical'ly analyzed for ccepliance with the siting requirements of 10 CFR 100 (1, 4).
he joint Task Force also evaluated the potential consequences of Class 9 accidents, or those acci6ents involving subs:antial core dawge.
mis evaluation was based upon infor: nation provided in the Reactor Safety S udy (5),
which provided a quantitative assessment of not only the consequences, but also the procability of severe accidents.
Bis evaluation was i.portant because risks associated with nuclear power are dominated by low procacility, high consequence accidents.
l Quantity of Radioactivity Released i
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At the time emergency planning regulations were 6eveloped, the RSS
.j represented the state of the art for evaluating the procacility and consequences of severe nuclear power plant accidents. The Paacter Safety Study h
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(RSS) provided information on the quantities of radioactivity released, t
radionuclides which dominate for various exposure patnways, timing of
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i radioactive releases, ene ical. for=s and availaoility of radioactivity following an accident, and virtually all other factors affecting :ne consequences of a reac:or accident.
dese fac ors taken together 6etermine I
what is known as the " source tern" for a particular accident.
S e RSS source terms for severe accidents were used to determine severe accident consecuences which were in turn used in the development of emergency planning regulations.
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Meteoral 1 Cbnditions
. The meteorological conditions at the time of and following a release of radioactivity play a. significant role in detemining the. consequences of the
- release, ne calculations of the consequences of a postulated DBA-IDCA presume "five percentile" meteorology.
2at is, it is assumed that atnospheric dispersion at the time of the accident should be less favorable then that which occurs 95% of the time.'
nese calculations are dependent upon site specific meteorological data which is mllected during the pre-operational period.
Five percentile meteorology represents worst case meteorology and projects generally high dose rates for a given release.
Determination of the Plume P re Pathway EPZ d
Se joint Task Force reviewed the offsite consequences for DBA-IOCA scenarios for seventy nuclear power plant sites.
Sey found that the higher PM plume exposure values (25 rem thyroid, 5 rem whole body)- would not be exceeded beyond 10 miles for any site analyzed.. Rey also found that the lower, more restrictive PM plume exposure values (5 rem thyroid,1 rem whole body) would not be exceeded beyond 10 miles for cner 70% of the sites.
"Frctn these results, the Task Force mncluded that about a 10 mile Emergency Planning, Zone for the plume exposure pathway was justified to assure that predetermined actions would be planned in those areas where PMs could be exceeded in the-event of a release comoarable to a design basis accident" (1).
Se joint Task Force also evaluated the relative probabilities - of -
certain critical ~ doses (characteri::ed by significant early injuries) occurring as a function of distance frca the point of release for the accident categories analyzed by the RSS.
off suestantially at about 10 miles from the reac:or" (1).2ey found that "...the pro the joint' Task Force to determine that the 10 mile DZ would oe effective in2is finding led dealing with core melt accidents.
TECENIOL BASIS FOR BG2 Tduu:.sc BGE's request to reduce the plume exposure pathway DZ from 10 miles.
to 2 miles is based upon the asser: ion :nat a 2 mile DI is adecp; ate to achieve tne objectives of the rule establishing a plume exposure pathway D: of 10 miles.
. In reaching this conclusion B32 condue:ed analyscs similar to trose the joint Task Force condue:ed in determining an appropriate radius for tne plume exposure pathway D2, i.e.,
an evaluation of tne mnsequences 'of a spectrum of postulated accidents.
Tnese analyses incluoe po:ential consequences of DBAs as reported in the Final Safety Analysis Report Calvert Cliffs (6) and the results of recent research into the source te=s for for 1 severe accidents.
BGG evaluated DEAs for Calver: Cliffs in order to detemine stole body 60se as a function of distance from the point of release.
(2is is tne same exercise performed oy the join: Task Force for seventy power plan:s as described aoove.)
For Calver. Cliffs the higher PM plume exposure vnole body dose was not exceeded beycrd 0.4 mile and the lower PA3 plume exposure vnole body does was not exceeded beycad 1.4 miles (7).
Sus, PMs would not be exceeded beyord 2 miles with no protective actions taken.
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BGE also evaluated the potential consequences of Class 9 accidents.
'lhis evaluation is of critical i@ortance to BGE's request because it is based t
on new. information concerning source terms.
Fecent research which nore
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accurately defines the source terms estirated by the RSS indicates that source
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terms are signficantly lower ; than previously estimated. While additional research is ongoing, the Arerican Nuclear Society, the American Physical Society, the Industrial Degraded Core Rulemaking Progras, and the Nuclear Regulatory Comission have all published reports indicating that existing source terms are unrealistically conservative (8-11).
te NRC is conte:: plating several regulatory revisions based on the term research, including those energency planning regulations which source require the 10 mile EPZ.. !b such revisions, however, are expected in the inrnediate future.
his is 'because researen is not confirm source term reductions in all cases.
presently adequate to It may nonetheless be adequate to confirm source term reductions for a particular plant design at a particular site.
BGE has conducted site specific. evaluations for Calvert Cliffs using the revised source terms for severe accidents reported by the NRC in-its draft report NURm-0956 (9).
tese source terms, while specifically developed for another plant (Surry),
are applicable at Calvert Cliffs for some acciden:
sequences because of cc:=en plant features. Where NURm-0956 source terms were,
applicable, EGE hired the Stone and Webster Engineering Corporation to not conduct an engineering evalua: ion of additional accident sequences at Calvert Cliffs.-
Le results of these analyses show doses high enough to cause significant early injuries drop off substantially at acout 2 miles from the plant.
As described above, the joint Task Force found-10 miles to be suitable radius for the plume exposure patnway EPZ based sucstantially on two a
findings:
1)
At that distance, PAGs would not be expected to be exceeded for a 6esign basis ' accident even in the absence of protective actions:
and
- 2) At that distance, the core severe Class 9 accidents would no:
result in life threatening doses, even in the aosence of prorective actions.
descriced above, that both of Onese criteria, and tnerefore tn the EPZ, are me:
Cliffs.
with a plume exposure pat.way EPZ of 2 miles at Calver:
EVALGCICH T 'IEE BGE RIDCEST provisions of 10 CFR 50.12(a).BGE's request for an execption will be treated in acrord Se regula: ion states in part t.ut:
"The Cc= mission may, upon application by any interested person or upon its cvn initiative grant suca exenp-dens from the requirenents of the regula:icns in this part as it
y determines are authorized by law and will not endanger life or property or the ccm:en defense and security and are l
otherwise in the public interest."
Requests for exemptions ; under 10 CFR 50.12 are routinely handled entirely by Camission staff;- there are no provisions for public input or hearings under these regulations.
2e' NRC has stated, however, that this request will not be evaluated as such requests typically are. It is the NRC's intention to solicit public ccznment, including conducting hearings if necessary, -- on this request (12).
De State of. Mar intervene in these proceedings if it chooses to do so. yland will be able to he timing of.this evaluation has not yet been established.
deliberations on this issue are not constrained by any regulato:y tinetable. It
- h e NRC's is reasonable to expect that any action of' EG&E's request, e.g., solicitation of public comment, informal notice from the.NRC prior to the public announcementis seve actions.
of any such MMCMD S"aIE AGEN2 RIES IN DEGDCY PLANNDG te overall responsibility for radiological emergency planning in Maryland rests with the Maryland Emergency Management and Civil Defense Agency, (MDiCDA), an agency of the Depart:nent of Public Safety and Correctional Services.
MDiCCA was responsible for coordinating the developnent of Maryland's Radiological Dnergency Plan (REP) in accordance with federal guidance.
For annual exercises, and in the event of an actual emergency, MDiCDA activates its Dnergency Operations Center for directing the State's response, coordinates with the utility, implements any necessary protective actions. federal and local governments, and The Depart:aen of Health and Mental Hygiene (Dmi) is responsible for protecting the health of Maryland citizens.
In :ne event of a radiological emergency, DE4 is therefore responsible for assessing the potential consequences of an accident, and dete=ing protective ac lons necessary to prevent or reduce health effects.
me DEKd agency chiefly responsicle for condue:ing accident assess::ent and recennending protective actions is tne
' Office of Enviromental Progra-s'.
Division of Radiation Centrol (DRC). CRC participated in the develegnent of the REP and accident assess:nent procedures and tecnniques.
DRC provices an accidentFor annual exercises, and in the event of an actual emergency, assess::ent field teans to collect confi:natory data. team to caluelate 6::se projections and One Maryland Power Plant - Siting Program (PPSP), an agency of the Depart:nent of Natural Resources, provides tecnnical support to M.NCDA and DRC.
PPSP participated in the development of the P2P and acciden assessme:::
procedures and techniques. For annual exercises, and in the even of an actual emergency, PPSP provides Maryland's lead onsite technical recresenta iv participates in accident assessment and determination of nechssary p:rc e, and ac. ions.
ec:ive and potential accident consequences.PPSP contains the State's expertise in nuc nese are the major agencies for radiological planning and response in Ma:yland.
As such, each will play a role in tne revies of IG&E's request.
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a AcrtRL CEMGS pom=TNG FRCM AN DZ Tclu.nCN 2e major effect of reducing the plume expsure pathway EPZ for Calvert Cliffs from 10 miles to 2 miles would be the elimination of two counties, St.
Marys and Dorr.hester, from the EPZ.
mis would not necessarily effect either planning or response at the. local level. Newspaper stories have quoted officials from both counties as desiring to continue participating - in the emergency planning process even if the BG&E request is granted. Based on these planning even if BG&E's request is granted. statements, there would seem to The participation of each county government is somewhat dependent upon services provided by B3&E. In&E presently bears the expense of dedicated pnone lines, traintenance of conitoring equipnent, naintenance of radios, training, and the siren notification system.
Each local government the utility for initial notification during exercises and in the event of analso depends actual emergency.
Wtille the extent to wnich B3&E would desire to reduce its level of interaction with or financial coligation to counties which would be outside the EPZ if its requested was granted has not been firmly establisned, they have excressed a willingness to negotiate with counties to continue to provide some 'or all of these services (13).
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Plannine Basis for the Deve101.ent of State and tocal ' c5vern Badiolocical Emercency Resacnse Plans in Succort of Licht WR*er Nuclear Power Plants.
Protection Agency, NURE,-0396, December 1978.U.S. - teclear Regulat 2.
Mannal ' of Protective Ac* ion Guides and ProtectivjL Actions for Nuclear Inc4 dents.
U. S.
Dwirottnental Protection September 1975 (Revised June 1980),
- Agency, EPA-520/1-75-001, 3.
Criteria for Preceration and Evaluation of p2diolocical Emreenev Resconse Plans and Prenaredness in Suwcrt of Nuclear Pow U. S.~
NUP5-0654, November 1980.reclear - Regulatory ('aiesion and Federa 4.
Title 10 Code of Federal Regulations, Part 100 Reactor Site Criteria. U S tuclear Regulatory Caission.
5.
Reae or safetv 9:gdv:
An Assessment of Accident Pl@s in U.S. Cu+reial
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Nuclear Dower Plants _.
U.S.
Nuclear Regulatory Comission,* iaSE-1400_,
(NURE,-75/014), October 1975.
6.
Lbdated Final Safety Analvsis Recon - Calve *+ Clifh Nuclear Dover Plant Units 1 & 2. Baltinere Gas & Electric Cc pany, Dockets 50-317 and 50-318 _
7.
Imeter from A.E. Lundvall, Jr. (EG&E) to E. J. Eutcher (NRC), November 18, 1985.
8.
Recon of the Sbecial Corittee on Source W-s. American Nuclear Society I
Septe=cer 1984.
j 9.
Richard Wilson, et tbclear Power Plants," Egiews of Modern Pnwies, V. 57, N. 3, knerican Pnysical Society, July 1985.
- 10. Technology for Energy Corp., ?belear cowr plaat Reseense to Severe Accidents. Industrial Degraded Core Rule:.aung Progra:, Novemoer 1984 11.
M. Silberoerg, et al., Reassessment of the wehnical n h
. Source ases fo-re-4.aring J
S --s, Draft Repor:
for
- Comment, U. S.
Nuclear Iegulatorv Caission,1;UREG-0955, July 1985. -
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12.
Personal ec:::unication frcn David Jaffe (NRC) to Thanas E. Mage::e (PPSP) t Decemoer 6,1985.
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13.
Personal cer::unication f:cm "t:enas E. Forgette (BG&E) to Thomas E. Mage (PPSP), Dece=oer 19, 1985.
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