05000483/FIN-2007004-01
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Finding | |
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| Title | Licensee Practices Allow Protective Action Recommendations for Areas Where Protective Action Guides Are Not Exceeded |
| Description | The licensee and offsite officials have implemented a protective action scheme in which the licensee makes recommendations for areas 2 miles in radius from the plant, and in -13- Enclosure affected sectors, sections 2 to 5 miles from the plant and sections 5 to 10 miles downwind, where a sector is a wedge-shaped area of the emergency planning zone marked by lines of radius 2212 of arc apart. Offsite officials make and implement protective action decisions in geographical zones which are typically several sectors \\\"wide\\\" and may cross the five and ten mile section boundaries. The NRC identified the licensee\\\'s implementation and understanding of procedure EIP-ZZ-00212, \\\"Protective Action Recommendations,\\\" Revision 21, allows the licensee to generate shelter or evacuation protective action recommendations for members of the public in areas of the emergency planning zone where radiological protective action guides have not been exceeded. Specifically, licensee processes allow protective action recommendations to be made for areas of the emergency planning zone 5 to 10 miles away from the reactor when those areas are not affected by the radiological plume. Federal guidance for the choice of protective actions during an emergency is described in EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA-400). Specifically, a protective action recommendation is warranted when radiation doses are projected between 1 and 5 rem (Total Effective Dose Equivalent) or between 5 and 25 rem (Thyroid Committed Effective Dose Equivalent); guidance further recommends that during the plume phase protective action decisions be based primarily on plant conditions and dose projections, without waiting for confirming environmental measurements. Federal guidance states that protective actions are seldom justified in areas where the protective action guides are not exceeded, based in part on minimizing the overall risk to the public. The licensee and offsite agencies have adopted a prompt protective action scheme based on EPA-400 and NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, Supplement 3, \\\"Criteria for Protective Action Recommendations for Severe Accidents.\\\" Upon declaration of a General Emergency classification the licensee recommends a minimum protective action of evacuation in a keyhole area 2 miles in radius in all directions, and evacuation to 5 miles in sectors affected by the wind, unless a radiological evaluation indicates a more extensive recommendation is required (under some conditions a shelter recommendation would be made). The inspectors determined the licensee procedure also provided for retaining protective action recommendations as meteorological conditions change, as discussed in Regulatory Information Summary 2003-12, \\\"Clarification of NRC Guidance for Modifying Protective Actions\\\" (that is, once a protective action is recommended for implementation, no reduction in the protective action recommended for that area is permitted). However, inspectors determined that, with an existing minimum keyhole protective action recommendation, when a wind shift is followed by an increase in radiological release severity, the licensee\\\'s practice is to recommend protective actions be taken between 5 and 10 miles from the plant in every emergency planning zone sector that previously had recommendations for actions between 2 and 5 miles from the reactor, regardless of the prevailing wind direction at the time when the radiological release increases in severity. The inspectors interviewed a group including licensee emergency planners, emergency response organization dose assessment staff, and licensee management, to determine the licensee\\\'s expectations and practices for making protective action recommendations -14- Enclosure under conditions of changing wind directions. The inspectors posed an example situation consisting of an initial two-mile 360 evacuation with three-sector evacuation between 2 and 5 miles downwind, followed by a slowly changing wind direction so that over a period of more than an hour the wind stabilizes at a direction opposite its initial direction (that is, a 180 wind direction change), followed more than an hour later by an increase in core damage severity requiring an extension of protective actions to 10 miles downwind. Licensee emergency planners, dose assessment staff, and management all strongly indicated that in the situation described the licensee would recommend an extension of protective actions to ten miles in all sectors along the 180 arc (that is, in any sector previously recommended for actions between 2 and 5 miles), and the licensee\\\'s recommendation would not be limited to the three affected sectors at the time core damage increased in severity. The inspectors determined the licensee\\\'s practice always result in appropriate protective action recommendations to offsite authorities for areas where there is radiological risk to the public, but under conditions of changing wind direction and release severity, the licensees practices can also result in recommendations to take actions in areas where dose assessment identifies radiological risk does not exist. The inspectors determined that the licensee had not adequately defined when an area of the emergency planning zone was affected by a radiological plume, in that a preexisting protective action recommendation for areas 2 to 5 miles from the plant should not automatically require future extension to areas 5 to 10 miles away in the absence of supporting radiological analysis (which may include appropriate professional judgement when the basis is described and documented). Inspectors determined that not increasing protective actions to include areas with no previous recommendation is not the same as reducing a previously-made recommendation, even for adjacent areas within the same sector; the 2 to 5 mile and 5 to 10 mile areas should be considered as distinct from one another in arriving at protective action recommendations. This issue has been entered into the licensees corrective action system as CAR 200707375. This issue is unresolved pending consultation with the Federal Emergency Management Agency, because the issue involves licensee processes for making protective action recommendations to offsite officials: URI 05000483/2007004-01, Licensee Practices Allow Protective Action Recommendations for Areas Where Protective Action Guides Are Not Exceeded |
| Site: | Callaway  |
|---|---|
| Report | IR 05000483/2007004 Section 4OA7 |
| Date counted | Sep 30, 2007 (2007Q3) |
| Type: | URI: |
| cornerstone | Emergency Prep |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | B Baca B Henderson B Larson D Dumbacher G Pick K Clayton M Haire P Elkmann T Stetka V Gaddym Peckp Elkmann T Stetka V Gaddy C Ng D Dumbacher G George J Adams M Haire |
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Finding - Callaway - IR 05000483/2007004 | |||||||||||||||
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Finding List (Callaway) @ 2007Q3
Self-Identified List (Callaway)
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