ML20235A343
| ML20235A343 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1987 |
| From: | Bradburne J NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Asselstine, Bernthal, Zech NRC COMMISSION (OCM) |
| Shared Package | |
| ML20235A045 | List: |
| References | |
| FOIA-87-737 NUDOCS 8801120210 | |
| Download: ML20235A343 (6) | |
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,' i p nc,u f o, UNITED STATES
. [p j NUCLEAR REGULATORY COMMISSION s, -} , . . ,l WASHINGTON, D C. 20555 ,
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- "* May 11, 1987 ,
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&lC. W - j MEMORANDUM FOR: Chairman Zech Commissioner Asselstine Commissioner Bernthal Comissicner Carr
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FROM: John Bradburne, Director Congressional Affairs, GPA
SUBJECT:
UDALL SUBCOMMITTEE HEARING ON NRC )
LEGISLATIVE PROPOSALS On Thursday, May 7, the Subcommittee on Energy and the Environment held ,
hearings on four NRC legislative proposals, the Arizona + South Dakota !
Compact and the Nuclear Emergency Response Data System (ERDS) bill. The i hearing was chaired by Rep. Udall, the witness list is attached.
Chairman Zech read the Commission's short statement into the record, then l responded to questions from the Subcommittee. The Chaiman indicated that the Comission supported the ERDS bill and that he would not object if states have additional, off-site data to assist them dt: ring emergencies.
He would also support grandfathering existing state data systems. Edward Jordan indicated that the NRC is planning voluntary implementation of the ERDS system over the next five years.
Mr. McMeekin indicated that Duke Power had questions concerning the need, practicality and cost for near real time data transmission. A copy of his testimony is attached.
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l CONTACT: Frederick Combs x-41443 Attachments:
As stated .
AE00 GPA/H. Denton C. Kamerer, SLITP J. Fouchard,PA J. Shea, IP 8801120210 880107 \ I PDR FOIA SHOLLYB7-737 PDR
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U.S. HOUSE OF REPRESENTATIVES COMMITTEE ON INTERIOR AND INSULAR AFFAIRS SUBCOMMITTEE ON ENERGY AND THE ENVIRONMENT
, HEARING - ,
ON H.R. 1316, H.R. 1317, H.R. 1318 H.R. 1319, H.R. 1530 AND H.R. 1570 Thursday, May 7, 1987 Room 2203 Rayburn HOB 9:45 a.m.
l WITNESSES The Honorable Lando W. Zech, Chairman, Nuclear Regulatory Commission l Mr. T.
C. McMeekin, Chief Engineer, Electrical Division, Design Engineering Department, Duke Power Company L
H.R. 1316 -
To amend the Atomic Energy Act to make it a Federal crime to carry.or otherwise introduce or cause to be introduced any dangerous weapon or other dangerous instrumentality onto sites regulated by the Nuclear Regulaiory Commission H.R. 1317 l To amend the Fnergy Reorganization Act of 1974 to clarify notification requirements for noncompliance,.and for other purposes H.R. 1318 To amend the Atomic Energy Act to provide criminal sanctions for an set of sabotage of a nuclear powerplant during its construction which would affect the public health and safety were it to go undetected H.R. 1319 To amend'the Atomic Energy Act to clarify that the Nuclear Regulatory Commission is authorized to protect from public disclosure certain sonstive generic safeguards information, the disclosure of which could negate or compromise site specific security measures H.R. 1530 Western Low-Level Radioactive Waste Disposal Compact Consent _Act H.R. 1570 Nuclear Power Emergency Response Data System A,ct of 1987 1
STATEMENT OF T. C. MCMEEKIN ON H.R. 1570 - NUCLEAR POWER EMERGENCY RESPONSE DATA SYSTEM ACT OF 1987 BEFORE U.S. HOUSE OF REPRESENTATIVES COMMITTEE ON INTERIOR AND INSULAR AFFAIRS SUBCOMMITTEE ON ENERGY AND THE ENVIRONMENT MAY 7, 1987 I. INTRODUCTION AND BACKGROUND My name is T. C. McMeekin. I am Chief Engineer, Electrical Division, Design Engineering Department of Duke Power Company. I appreciate the invitation to l appear before this su'ocommittee.
The purpose of my testimony is to provide Duke Power's perspective on H.R. 1570 - Nuclear Power Emergency Response Data System Act of 1987 and on the
- subject of Emergency Response Data Systems in
- general. I made similar testimony to this j subcommittee on H.R. 5192 on August 11, 1986. i As a result of post-accident evaluation of the l March, 1979 accident at Three Mile Island, there was significant activity in the development of emergency response capabilities. These activities resulted in numerous industry and NRC initiatives. This activity culminated in the development of several documents including NUREG 0737 (Clarification of TMI Action Plan Requirements). Supplement I to the NUREG 0737 (Requirements for Emergency Response Capability) and i associated NUTAC'(Nuclear Utility Task Action Committee) Guidelines on Emergency Response Capabili-ties.
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1 H.R. 1570 - NUCLEAR POWER EMERGENCY RESPONSE DATA SYSTEM ACT OF 1987 PAGE 2 4 II. CRISIS MANAGEMENT PHILOSOPHY The Duke Crisis Management Plan was developed on the basis that four basic functions must be carried j out in an emergency. They are:
Plant Operation Accident Assessment Emergency Management Protective Action Recommendations In the event of an accident, all functions are initially the responsibility of the station. After activation of the Crisis Management Center (CMC), the station is relieved of Emergency Management and development of Protective Action Recommendations.
The station is always responsible for Plant Operation and Accident Assessment.
This approach was adopted because dynamic plant conditions can only be effectively assessed and j managed by the on site staff. This staff has available current plant information which includes readings from plant monitors, measurements from test ;
equipment, out of service status, physical damage '
assessments, and other subtle indicators. Such current information cannot be effectively trans-mitted off site.
III. DUKE EMERGENCY RESPONSE DATA SYSTEM j Duke, and the industry in general, has. implemented !
crisis management plans, operating procedures, and related hardware to substantially improve emergency response effectiveness. These plans, procedures and systems were developed based on NUREG 0737 Supplement '
1 requirements and associated NUTAC guidance and submitted for NRC review and approval.
The Duke Emergency Response Data System design considerations included user responsibility, importance of data validity, system reliability, etc.
The system provides for on site real time data acquisition and off site data subsets which are periodically updated. On site NRC representatives have access to this same real time data and the off site NRC representatives have access to the periodically updated data subsets.
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H.R.
1570 - NUCLEAR POWER EMERGENCY RESPONSE DATA SYSTEM ACT OF 1987 PAGE 3 l
I V, . DUKE POSITION ON H.R. 1570 While we are always interested in evaluating better techniques for. emergency response and'in i sharing plant inform & tion with the NRC, we have concerns with H.R. 1570. Although H.R. 1570 represents an improvement over H.R. 5192, we have several concerns related to the need, practicality, and cost for near.real time data transmission to off site facilities. The concerns are summarized below:
Need o Given that plant informa tion . is currently avail-able to the on site NRC staff-through real time monitors and to the Region and Bethesda offices through periodically updated data subsets, we question the benefit of mandating an automatic electronic data transmission system.
Practicality o
As a practical matter, automatically transmitted data will necessarily be incomplete-as it relates to total plant status. It is simply impractical to transmit total plant status off site. Any type
'of electronic data transmittal will require voice supplement to ensure proper perspective. Recog- 1 nizing the impracticality and that management of dynamic conditions must be done on site, we feel that near real unnecessary. time off site data transmittal is Cost o Depending on the scope of the system; i.e., the ;
number of measurements and the frequency of update; utilities could incur a substantial cost to develop and maintain an interface between the plant and the Emergency Response Data System.
Stability o To fully realize the benefits of the substantial modifications to plaJ t design and operating ;
I procedures installeT since the TMI accident, it is '
important that the industry have a period of regulatory stability.
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l H.T. l 1570 - NUCLEAR POWER EMERCENCY RESPONSE DATA SYSTEM ACT l OF 1987 '
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I o Other In addition to the comments above, we have the following additional concerns on H.R. 1570: I o It includes no clear limitations on the scope !
of the system or who the users me.y be. l l
o Further, it would require additional informa- l tion in support of electronically transmitted data which might further burden the utility in an emergency.
o The proposed system is not limited to emergency use. I o
It is not clear that the official NRC recommen-dations would be limited to a single communica-tion channel (e.g., the Senior NRC official at the CMC).
o To date, the Emergency Response Capability requirements have been issued via a NUREG and ,
utilities responded to an associated generic letter. The resulting action plan was confirmed through an NRC confirmatory order. I If further emergency response requirements are warranted, we think a similar process would be appropriate.
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SUMMARY
l In summary, we have concerns related to the need, practicality, cost, and numerous scope uncertainties related to this Bill. We believe that current Crisis Management Plans adequately provide data for the licensees and the NRC to fulfill their responsibil~
ities. In light of these comments, we do not feel that this Bill would be in the best interest of the nuclear industry. To the extent that enhancements are to be considered, we believe that the existing regulatory process is appropriate to evaluate and implement as appropriate. I urge this subcommittee to consider these comments in your deliberations.
Thank you for the opportunity to appear before you ,
l today.
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