NRC-96-0129, Provides Comments on Draft Suppl 3 to NUREG-0654/FEMA-REP-1, Rev 1, Criteria for Preparation & Evaluation of Radiological Emergency Response Plans & Preparedness in Support of Nuclear Power Plants
| ML20134P931 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/22/1996 |
| From: | Smith P DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-96-0129, CON-NRC-96-129, RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 9611290384 | |
| Download: ML20134P931 (2) | |
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Fermi 2
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ia November 22,'1996 l
NRC-96-0129 i U. S. Nuclear Regulatory Commission i
Attn: Document Control Desk' l
. Washington, D. C. 20555
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References:
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Fermi 2.
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NRC Docket No. 50-341 NRC License No. NPF-43
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Federal Register 61FR43794-43795, dated Monday, August 26, 1996, Federal Emergency Management Agency - Notice of l
Interim Use and Comment Document: Criteria for Preparation j
and Evaluation of Radiological Emergency Response Plans and i
Preparedness in Support of Nuclear Power Plants (Criteria for Protective Action Recommendations for Severe Accidents) 3)
Draft Supplement 3 to NUREG-0654/ FEMA-REP-1, Revision.
l 1," Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of I
Nuclear Power Plants" l
Subject:
Fermi 2 Comments on NUREG-0654 Draft Supplement 3 Reference 2 provided notice that the Reference 3 document is available for interim use, public review, and comment, and that comments should be submitted within 90 days of the notice. The purpose of this letter is to provide Detroit Edison comments on the Reference 3 draft supplement based on emergency planning program implementation experience at the Fermi plant.
i The staff of Fermi 2 have reviewed the updated guidance for offsite protective action recommendations contained in Draft Supplement 3 to NUREG-0654/ FEMA-REP-1.
l We agree in concept with the revised guidelines, but would recommend mprovements in execution to realize the desired " simplified guidance on protective ogO,1 O
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actions for severe reactor accidents". That is, although the guidance has clearly changed, the effort to provide " simplified guidance" does not appear to be effective i
due to inconsistent duplication of terminology. Simplification in this area is important to ensure consistent application toward protection of the public.
Ambiguous terminology is used throughout the text, and carried into the proposed flowchart. Inconsistent use of phrases like " severe (reactor) accidents,"
" substantial core degradation," and " severe core damage", add inappropriate subjectivity contrary to the concept of simplification. Reference to the " potential for containment failure" appears to be unnecessary when linked to the former examples.
Lacking further definition, any." substantial core degradation or melting" event might alone be considered to represent an unacceptable potential for containment failure.
Inconsistent inclusion of this consideration, adds another subjective decision point. A simplified process should provide objective guidance which makes the intent clear.
The intent of the proposed supplement appears to be that the proposed protective actions are implemented upon General Emergency declaration. This conclusion is reached by comparing the descriptions of the conditions warranting evacuation to the general emergency " Class Description" of Appendix 1. The desired simplification could be achieved by eliminating the above mentioned subjective terminology, and use j
the common well understood term, " General Emergency", to describe the wndition requiring evacuation.
If you have any questions on this letter, please contact Mr. Kevin Morris at (313) 586-4327.
Sincerely, Peter W. Smith Director, Nuclear Licensing cc: A. B. Beach M. J. Jordan A. J.
Kugler A. Vegel
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