ML13130A185

Evacuation Time Estimate (ETE) Update for the Limerick Generating Station (LGS) Site

ML13130A185
Person / Time
Site:	Limerick
Issue date:	06/04/2013
From:	Mark Thaggard NRC/NSIR/DPR/DDEP
To:	Cuthbert L Alliance For A Clean Environment
References
Download: ML13130A185 (3)

Text

June 4, 2013 Dr. Lewis Cuthbert, President The Alliance for a Clean Environment 1189 Foxview Road Pottstown, PA 19465

SUBJECT:

EVACUATION TIME ESTIMATE UPDATE FOR THE LIMERICK GENERATING STATION SITE This letter is in response to your emails dated April 18, 2013, and March 29, 2013, regarding concerns related to the December 2012 update to the Evacuation Time Estimate (ETE) for the Limerick Generating Station (LGS) site. Issues raised by members of the public are important aspects of the U.S. Nuclear Regulatory Commissions (NRC) mission to ensure the adequacy of offsite plans and preparedness, in coordination with the Federal Emergency Management Agency (FEMA). It is in this spirit of openness that we continue to offer to discuss the issues with our organization, as well as working with you to reach a common understanding of the NRC actions regarding reviews of the ETEs.

We have exchanged emails on this topic and, as discussed in the April 18, 2013, email from Mr. Joseph Anderson of my staff, the recent Emergency Preparedness Rule, implemented in December 2011, revised 10 CFR Part 50 to state that an ETE is to be used by a nuclear power reactor licensee in the formulation of protective action recommendations and is provided to State and local governmental authorities for use in developing offsite protective action strategies. As such, an ETE serves as a planning tool that is primarily used to inform protective action decision-making, but may also be used to assist in the development of traffic management plans to support an evacuation. As a planning tool, there is no regulatory threshold established for a maximum (or unacceptable) evacuation time developed under the ETE study. Rather, the ETE study serves as one of many tools for assisting the Commonwealth of Pennsylvania in formulating a protective action decision for the various evacuation scenarios analyzed.

For additional insights, our previous email regarding the scope of the NRC review is discussed in the Statement of Considerations for the recent Emergency Preparedness Rule. The Statement of Considerations discusses that the NRC does not approve ETE updates but will review them for completeness using the guidance in NUREG/CR-7002, Criteria for the Development of Evacuation Time Estimates, dated November 2011 (NRC Agency wide Documents Access and Management System (ADAMS) Accession No. ML113010515). The results of the staffs review of the LGS ETE update, when completed, will be documented in the NRC Resident Inspectors Quarterly Report, which will be publicly available.

With the ETEs used to support protective action decision-making during an event, the respective offsite response organization uses the implementation of emergency plans in support of an evacuation. The basis for this use of ETEs is established in Section 5.3 of

L. Cuthbert NUREG/CR-7002, which states: Interaction with state and local agencies is necessary to obtain local and regional data, understand the operations and resources of the emergency response capabilities, and understand the traffic management system. Therefore, part of the agencys completeness review is to look for licensee documentation of those State and local agencies contacted and the extent of interaction with these agencies related to the development of the ETE.

As reflected in the April 22, 2013, letter from R. W. Borchardt (NRC Executive Director for Operations) to The Honorable Jim Gerlach, I continue to encourage you to contact Mr. Joe Anderson at (301) 415-4114 to discuss any specific concerns with the LGS ETE update and to provide answers to any questions that you may have on the ETE process and the agencys review. Any specific concerns you have regarding the adequacy of offsite response organization emergency plans to implement an evacuation for the LGS site may also be discussed with, and will be forwarded to, FEMA per a Memorandum of Understanding between FEMA and the NRC.

We look forward to discussing with you, in a mutually agreeable venue, your concerns and insights regarding the December 2012 ETE update for the LGS site.

Sincerely, Mark Thaggard, Acting Director /RA/

Division of Preparedness and Response Office of Nuclear Security and Incident Response cc: The Honorable Jim Gerlach United States House of Representatives Andrew Mitchell, Director FEMA Technological Hazards Division

L. Cuthbert NUREG/CR-7002, which states: Interaction with state and local agencies is necessary to obtain local and regional data, understand the operations and resources of the emergency response capabilities, and understand the traffic management system. Therefore, part of the agencys completeness review is to look for licensee documentation of those State and local agencies contacted and the extent of interaction with these agencies related to the development of the ETE.

As reflected in the April 22, 2013, letter from R. W. Borchardt (NRC Executive Director for Operations) to The Honorable Jim Gerlach, I continue to encourage you to contact Mr. Joe Anderson at (301) 415-4114 to discuss any specific concerns with the LGS ETE update and to provide answers to any questions that you may have on the ETE process and the agencys review. Any specific concerns you have regarding the adequacy of offsite response organization emergency plans to implement an evacuation for the LGS site may also be discussed with, and will be forwarded to, FEMA per a Memorandum of Understanding between FEMA and the NRC.

We look forward to discussing with you, in a mutually agreeable venue, your concerns and insights regarding the December 2012 ETE update for the LGS site.

Sincerely, Mark Thaggard, Acting Director /RA/

Division of Preparedness and Response Office of Nuclear Security and Incident Response cc: The Honorable Jim Gerlach United States House of Representatives Andrew Mitchell, Director FEMA Technological Hazards Division Distribution:

C. Miller (Region I)

N. McNamara (Region I)

A. Dimitriadis (Region I)

M. Grey (Region 1)

S. Burnell (OPA)

G. Dacus (OCA)

W. Gott (NSIR)

R. Rihm (OEDO)

ADAMS Accession No. ML13130A185 OFFICE BC:NSIR:DPR OCA Region I D:NSIR:DPR NAME J. Anderson G. Dacus* J. Clifford* M. Thaggard DATE 5/10/13 5/10/13 5/30/13 5/30/13 OFFICAL RECORD COPY

• Concurrence documented in email.