ML19207B749
| ML19207B749 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/31/1979 |
| From: | Galpin F ENVIRONMENTAL PROTECTION AGENCY |
| To: | Ryan R NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| RTR-NUREG-0553, RTR-NUREG-553 NUDOCS 7909050204 | |
| Download: ML19207B749 (2) | |
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O i UNITED STATES ENVIRONMENTAL PRCTECTICN AGENCY i
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w A s n i NG TO N OO ;;4;
.y Mr. Robert G. Ryan Chair =an, Federal Interagency Central Coordinating Committee (RERP)
Office of State Programs U.S. Nuclear Regulatory Coc=ission Washington, D.C.
20555
Dear Bob:
Thank you for the opportunity to review and cec =ent on "Beyond Defense-in-Depth," NUREG-0553 This is an excellent and valuable reference for our grcwing librar-/ of emergency response planning documents. The esti=ated costs for the preparation of e=ergency plans is useful information in assessing the cost effectiveness aspects of deriving Protective Action Guides since these costs, en a centinuing basis, can become very substantial.
I believe we should further explore the concept of requiring NRC
" approved" State and local emergency response plans as a condition of licensing and operation of nuclear power plants. As I understand the situation, this would require new legislation. Also, NRC's present concurrence mechanism =ay need to be reevaluated to make the concurrence activity more meaningful. The current concurrence procedures basically approve a State radiological emergency response plan (i.e., a piece of paper), but, until very recently, had no requirement that the plan be tested prior to concurrence.
I understand frcm NRC's 1978 annual report that successful testing of plans has very recently been incorporated as a condition prior to issuing concurrence. Although this is a step in the right direction, it does not, in all cases, guarantee that local plans have been coordinated with and integrated in the State plan, nor that'these local plans can be successfully tested. Participation of local authorities in the overall State plan is, in my opinien,. essential to successful implementation of the overall plan.
It may be that concurrence needs to be staged in phases, i.e.,
(1) the plan, (2) testing, and (3) periodic retestings. Perhaps we could get together scon to discuss our views on the develcpment of local plans and the integrated testing of State plans with utility and local governmental plans.
I 1 1?I ui 90005 0:2 C)d7'
2 It is clear that the current hybrid approach to funding emergency response planning is not the answer to the current problems in planning. The recommendation of the draft report that utilities fund State and local planning efforts through increased licensing fees levied by NRC initially appears to be an attractive alternative. Since tha report raises this central issue of funding by utilities, I feel that this issue should be addressed separately and be evaluated in light of its advantages and disadvantages before I could completely agree with such an approach.
If you have any questions concerning my comments, please call me.
Sincerely yours, Director Environmental Analysis Division Office of Radiation Programs ( ANR 461) cc: Harold Collins
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