ML19260E069

Responds to Questioning Smaller Low Population Zone for Facility than for TMI Where Power Level Is Greater. Low Population Zone Selected by Applicant,Must Meet Radiologic Dose Requirements & Be within Guideline

ML19260E069
Person / Time
Site:	Limerick
Issue date:	01/30/1980
From:	Ballard R Office of Nuclear Reactor Regulation
To:	Seidts M AFFILIATION NOT ASSIGNED
References
NUDOCS 8002130272
Download: ML19260E069 (11)

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UNITED STATES 3"

NUCLEAR REGULATORY COMMISSION 3

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JAN 3 01980

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Docket Nos. 50-352 and 50-353 fis. Marlene G. Seidts W. 7 Stars Road Phoenixville, Pennsylvania 19460

Dear Ms. Seidts:

This letter is in reply to your letter to Harold Denton dated December 10, 1979, on the Limerick Generating Station.

In response to your question why the LPZ for Limerick is smaller than that for TMI when the power level is greater, it should be pointed out that the LPZ distance is selected by the applicant, rather than the NRC, but must meet the requirement that the radiological doses to an indivf asal on the outer boundary from a postulated accident must be within the guideline values given in 10 CFR Part 100.

In addition, since the resul t.ing doses to an individual are affected by the plant engineered safety features as well as the power level, it is possible, for example, for two different plants of similar power level to have quite different LPZ values. Also, for both the TMI and Limerick plants, the LPZ distances chosen by the respective applicants were greater than the minimum distances which would have been necessary to meet the guideline dose values of 10 CFR Part 100.

At the time of the Limerick CP review, emergency planning was generally considered to be adequate if it encompassed the LPZ. As a result of the recommendations of a joint NRC/ EPA Emergency Planning Task Force in December 1978, as well as the experience gained from the accident at Three Mile Island, the NRC has proposed to revise its regulations on emergency planning (A copy of the proposed rule is enclosed.) This proposed rule would extend emergency planning out to distances of about 10 miles for the plume exposure pathway and about 50 miles for the ingestion exposure pathway.

If the proposed rule takes effect, it would effectively make the LPZ obsolete for purposes of emergency planning.

The NRC staff has recently requested power reactor licensees to submit information on evacuation estimates of various areas around the reactor out to a distance of about 10 miles (Enclosed is a copy of the November 29, 1979 request sent to all power reactor licensees).

You will note that the information requested includes time estimates for an adverse weather estimate as well as a best estimate.

The staff intends to request the same, or very similar, information fro. the applicant for the Limeri.k station, and to evaluate this information for adequacy prior to the issuance of an operating license.

h 8002130 2 92

Ms. Marlene G. Seidts You have asked why we do not retroactively consider a coal plant at the Limerick site or consider converting the existing structures to a coal plant.

An evaluation of such alternatives must be made from the present time consider-ing construction already completed and the time the plant is needed.

Little, if any, of the current construction could be used efficiently for a coal plant.

It would be better from a life-time electricity generating cost standpoint to build a complete new coal facility if the existing nuclear construction permit were withdrawn.

Converting to coal plant will cause the loss of about

$1.4 billion (the investment in place as of September 30,1979).

In addition, conversion of Limerick to coal would require five more years to achieve commercial operation than would completion of the nuclear units. This results in replacement power costs on the order of $20 million per month. Since a public utility derives all of its revenues from its customers, any action which increases costs is ultimately borne by its customers.

If the staff were to do a reevaluation of the Limerick Construction Permit based upon updated population guidelines, the evaluation must also include the latest information available on other health and safety issues of nuclear, as well as the health and safety impacts of coal.

Since the issuance of the Limerick Environmental Statement, the staff has determined that the public health and safety impacts of a coal plant are much greater than for a nuclear plant.

This conclusion is also reached in a number of other studies, most recently in a major study donc by the National Academy of Sciences, " Energy in Transition," Wa shing ton, 1979.

Thus, the replacement of the Limerick station would result in a higher health and safety risk to the public.

The life-time generating cost for a coal plant in Pennsylvania is likely to be about 30% greater than for a nuclear plant even if both were to begin operation at the same time.

The difference would be much greater if the construction already under way is abandoned.

Therefore, no net public benefits either in dollar costs or in health and safety costs would result in changing from a nuclear to a coal plant.

Regarding your concern about seismology, the statement in NUREG-0625 (page 28) concerning the identification of surface faulting as a current basis for rejecting the suitability of a proposed nuclear plant site pertains to proposed sites where the location of a capable fault as defined in 10 CFR 100, Appendix A has been established. The extensive geologic studies conducted at the Limerick site have shown that capable faults within the definitions of Appendix A criteria are not present at the Limerick site. The staff of the NRC following their review have agreed with this conclusion and do not consider surface faulting which could be caused by geologic activity to be an unresolved safety issue at the Limerick plant site.

Ms. Marlene G. Seidts Currently the U. S. Geological Survey has been asked to evaluate the effects of nearby blastirg on performance of the Limerick plant and to assess the likelihood that this blasting could reactivate old faults at the site. The energy that is rt.. eased from man-made activities such as blasting can be scheduled, controlled and monitored and is small in comparison to the energy which is unleashed from uncontrolled seismic and geologic events such as earthquakes and large fault displacements. The staff will issue review find-ings on this concern of nearby blasting upon completion of this evaluation.

You also expressed concern about water use and consumption by the Limerick station. The Delaware River Basin Commission (DRBC), the agency responsible for water supply and water quality matters concerning the Delaware River and its tributaries, will regulate water use and consumption by the station to assure adequate water supplies of acceptable quality in the Delaware River Basin.

Regulation by the DRBC was taken into account by the i1RC in its environmental review of Philadelphia Electric's application for the Limerick units.

If you have any further questions or comments on the Limerick project, please feel free to contact me at any time.

Sincerely, Q

s n & g ' D h a L d' Ronald L.'Ballard, Chief Environmental Projects Branch 1 Division of Site Safety and Environmental Analysis

Enclosures:

1.

Proposed rule 2.

Letter to licensees dtd 11/29/79

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• Na Propos6d Rules Vol. 44. No. 245

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Wednesday, December 19, 1973 2

Ths secton cf the FEDERAL REG' STER significant for the nuc! car powcr plant in automatically require nuclear power confins neti:cs to the put,Lc of the question, that altcmative compensating plant shutdcwn for lack of concurrence pqposed issuanco of rules and actions have been or will be taken in appropriate State and local

,ppat.ons. Tno pwposo of these netccs promptly, or that there are other government emergency response plana is t) gao interested perscns an compc!!ing reasons for license issuance.

on the date specificd in the rule un! css

2. For nuc! car power reactors already an exemption is grant:d by that date. It ghertINo $pfen cf f'nal h.eensed to operate,if appropriate State would:

• 3 and local emergercy respense plans

1. Requre NRC concurrence in the have not roccived NRC concuence appropriate State and loccl government

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NUCLEAR RIGULSTORY within 100 days after the effective date emergency response plans prior to COMW3SIO,'J of this amendment or by January 1,1031, operating license issuance. However, whichever is sooner, require the the Commission can grant an excmption 10 CFR Part 50 Commission to determine whether to from this requirement if the applicant require the licensee to shut down the can demonstrate to the satisfaction of Emergency Plann!r,3 reactor. lf at the time the Commission the Commission that dcficiencies in the finds that the licensce has demonstrated p!ans are not significant fcr the piant la AGENCY; U.S. Nucicar Regulatory that the deficiericies in the plans are not question, that altctnative compensating Co nmission.

significant for the plant in question, that actions have been or will be taken ACT:CN: Proposed Rule.

nlternative compensating actions have promptly, or that there are other hlUMAny:The Nuclear Regulatory been or will be taken prompt!y, or that compelling reasons for license issuance.

Commission, after considering the public there are other compelling reasons for No such cperating license wi!! be issued record available concerning licensce, continued operaticn, thcn the licensee un! css NRC finds that appropriate State and loca! govemment emer;ency may continue operation.

protective acticns, including evacuatica preparedness, and the need to enhance if at that tim 'he Commission cannot when necessary, can be taken for any pro!cction of the pub!!c health and make such a fin ag, then the reasonably anticipated population safety,is proposing to amend its Commission will order the licensee to within the plume exporsure EPZ.

regulations to provide an interim show cauce why the p! ant should not be

2. For nuclear power reactors already tpgrade of NRC emergency p!anning shut down. In cases of serious licensed to operate, require a licensee to regula! Ions. In a few areas of the deficiencies. the order to show causa shut down a reactor immediately if proposed amendments, the Commission will be made immediate!y cffective and appropriate State or local emergency has identified two aircrnatives which it the licensee would be required to shut response plans have not received NRC is considering. In each instance both down the reactor, concurrence within ISO days of the alternatives are presented in the

3. For nuclear power reactors already effcctive date of the final amendments f.

following summary of the proposed licensed to operate,if appropriate State or by January 1,121, whichever is changes and in the specific proposed and local cmergency respcase plans do sconer. However, the Commission may ru!c changes presented in this notice.

not warrant continued NRC ccncurrence grant an exemption from this 7ae final rule will not necessarily and the State or locality do not correct requirement if the licensee can incorporate all cf the first alternatives or the deficier.cies within 4 months of demonstrate to tha satisfaction cf the allof the second alternatives.That is,in notification by the NRC cf withdrawal Commissica thct the d:ficiencies in the some instances the first alternative may of its concurrence, require the plans are not significant for the plant in be adopted and in others, tha second Commission to determine whether to question, that alternative compensating a!temative may be adoptcd. Further require the licensee to shut down the actions have been or will be taken alternatives rnay be adopted as a result reactor. Shut down may not be required promptly, er that there are other cf consideratien of public comments, if the Commission finds that the licensee compelling ressens for continued in one alternative (A!!ctnative A), the has demonstrated that the deficiencies operation. If there is no coacurrence, proposed rula change would not in the plan are not significant for the and the p! ant is shut down, then it must automatica!!y require suspension cf plant in question, that alternative remain shut down until such an operations for lack of concurrence in compensating actions have been er will exemption is granted or until apptcpriate State and local gos ernment be taken promptly, or that there are concurrence is obtained.

emergency response plans on the date other comptiling reasons for continutd

3. For nuc! car power reactors already specified in the rule, even if the operation.

licensed to operate, require a license to Commission by that date has not yet if at this time the Ccmmission cannot shut down a reacter if appropriate State determined whether the reactor shculd make such a finding, then the or local emergency response plans do be allowed to coatinue to operate. 't Commissien will order the licensee to not warrant continued NRC concurrence would:

show cause why the plant should not be and the State or locality does not correct

1. Require NRC concurrence in the shut down. In cases of serious the deficiencies within 4 months of appropriate State and local govctnment deficiencies, the order to show cause notification by the NRC of withdrawal emergency response plans prior to will be made immediately effective and of its concurrence. Ilowever, the operating license issusnce, unless the the licensee would be required to shut Commission can grant an exemption to applicant can demonstrate to the down the reactor.

this requirement if the licensee can satisfaction of the Commission that in the other alternative (Alternative demonstrate to the satisfaction of the deficiencies in tha plans are not B), the proposed rule change would Commission that the deficiencies in the 0

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75163 Federal Register / Vol. 44 No. 245 / Wednesday, Decemb r 19. 1979 / Proposed Rules s

plan are' dot significant for the plant !a proposed rutcmaking described in this to be submitted to and concurred in by

" question, that alternative compensating notice responds to that request and has the NRC as a condition of operating actions have been or will be taken been prepared on an expedited basis.

license issuance, riemptly, or that there are other Consequently. considerations related to Under one alternative being compelling reasons for continued the workability of the proposed rule may considered, the proposed rule would cperation. If there is no concurrence and have been overlooked and significant require a determination on continued the plant is shut down then it must impacts to NRC. applicants, licensees, operation of plants where relevant State remain shut down until such an and State and local governments may and local emerger.cy response plans exemption is granted or until not - tve been identified. Therefore, the have not received NRC concurrence.

concurrence is regained.

NRC particularly seeks comments Shutdown of a reactor would not follow In both alternatives the proposed rule addressed to these points and intends to automatica!!y in every case. Under the would:

hold workshops prior to preparing a other alternative proposal, r.hutdown of

4. Require that emergency planning final rule to (a) present the proposed the reactor would be required considerations be extended to rule changes to State and local automatically where the appropriate

" Emergency Planning Zones."

governments, utiities, and other State and local emergency response

5. Require that applicants' and interested parties and (b) obtain plans have not received NRC 1;censecs' detailed emergency planning comments concerning the costs, impacts, concurrence within the prescribed time implementing procedures be submitted and practicality of the proposed rule, periods. flowever, the Commission for NRC review.

The Nuc! car Regulatory Commission could grant an exemption to this

6. Clarify and expand 10 CFR Part 50 Is considering the adoption of requirement if the licensee can Appendix E. "Emer;cncy Plans for amendments to its regulation. "Domest.ic demonstrate to the satisfaction of the Production and Utihzation Facilitics."

Licensing of Production and Utilization Commission that the deficiencies in the DATES: Comments should be submitted Facilities," 10 CFR Part 50. that would plan cre not significant for the plant in on or before February 19.1920.

require that emergency response question, that alternative compensating Acontssts: Interested persons are plannirig considerations be extended to actions have been or will be taken invited to subrnit written ccmments and Emergency Plannmg Zones (d:scussed in promptly, or that there are other suggestions on the proposed ru!c NUREC-0399, EPA 523/1-73-010 changes and/or the supporting value/

Planning Dasis for the Developm'ent of compelling reasons. If there is no concurrence and the plant is shut down, impact analysis to the Secretary of the State and Local Government then the plant must remain shut down Commission. U.S. Nuclear Regulatory Radiological Emergency Response Plans until such an exemptica is granted or Commis sion, Washington, D.C. 20355, in Support of I.ight n ater Nuc! car, until concurrence is obtained.

.Attenticn: Docketing and Service Power Ilants J. Both the Commission Branch. Copics of the value/ impact and El A have formal!y endorsed the The NRC presently re9uires that analysis and of comments reccived by concepts in that EPA /NRC Report,41 FR pown reactor licensees and applicants the Ccmmission may be examined in the 01123 (October 28,1979). In addition, the plan for radiological emergencies within Commission's Public Document Room at Nuclear Regulato y Commission is their plant sites an make arrangements with State an oca organizations to 1717 H Street. NW., Washington. D.C.

considering revising to CFR Part 50, and at local Public Document Rooms' Appendix E. " Emergency Plans for respond to accidents that might have Sin ~!e copics of the value/ impact Production and Utihzation Facilities,"in c nsequences beyond the site boundary, analysis related regulatory guides, and order to clarify, expand. and upgrade In this way, offsite emergency response the NRC staff analysis of the public the Commission's emergency planning planning has been related to the nuclear comments receised on the Advance regulations.5 Prior to the conclusion of licensing process.

.- - Notice of Propo;ed Rulemaking may be this rulemaking proceeding, the To aid State and Icoal governments in ebtained on request.

Commission will give special attention the development and implementation of Y

S FCR FURTHER INFORMATION CONTACT:

including the need for concurred.in NRC, in conjunction with several other f.!r. hiich ael T. lamgocho.n. Office of plans, on a case-by-case basis in Federal agencies, has attempted. on a Standards Develcpment, U.S. Nuclear acccrdance with the rnodif:ed cooperative and voluntary basis, to Regulatory Commission, % ashington.

adjudicatory procedures of 10 CFR Part provide for training and instruction of D.C. 20a,aa (Telephone:301-H3-5930).

2, Appendix D.Under that Appendix,no State and local government personnel SUPPLEMENTARY INFORMATION: InJune new license, construction permit. or and to establish criteria to guide the 1979, the Nuclear Regulatory limited work authorization may be preparation of emergency response Comnussion began a formal ssued without Commission plans.8 Ifowever, in the past, the NRC reconsideration of the role of cmergency consideration ofissues such as this.2 has not made NRC concurrcnce in State planning in assuring the continued Doth versions of the proposed and local emergency response plans a protection of the public health and amendments call for State and local condition of operation for a nuclear safety in areas 'round nuclear power government emergency response plans powerplant; the prcposed rule would do facihties. The Ccmmission had begun so, as explained above.

this reconsiderat on in recognition of the

'Two NEC staff guidance documen's are related need for more off. ctive emergency to ihn rroposed ruie chanse. "Drafi Eme ency

'NRc sta!! guidance for the preraration and planning and in re: pcuse to reports Ac&n level Guidebres for Nuclear Power Plants."

evaluation of State and local emergea.cy response issued by responsible offices of Whihas pubbshed kr mtert;n use and plans lead; rat to NRC concurrence is conamed na 8

• "' " 8"'#" 211r9 h n mntcd aat NUREG rs/ int.-Gu;Je and Checkhst for

• ",n"al version of the action level guidahnes. basedDeve!opment and Eva!uston of State and I.ocal government am3 its Congressiona1 af ove'si ht Committees.

on the pubhc commen's ro ccited. mil be issue." in Gos e n ncnt Ra:!micaical Emergency Response 5

Uy memorandum dated July 31,1979, ear!y 1%a in additmn. m ear'y 19% upgraded.nd F%ns m Support of Faed Nuclear Facihties**

I the Commission requested that the NRC revised accept;.nce cran:a for evaluatmg IDecember 1.19:41 and surplement 1 thereto dated staff undertake expedited rulemaking on

'*""'""P'"d"'" A"" ma be iss ued for March is, im.1he adequacy of this yuidance is comment and rr..y be mciuded m the Comm;ssion,s be.rg rees aluated by the 6taff sr.J the Gw.m.ssion t e sugKct o State, oCal, and h.censee reg dato is.

mH cor.s: der co& Scat.on cf the upgraded cntena un emergency response plans. The

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Fdderal Register / Vol. 44. No. 245 / Wednesday Decernber 19. 1979 / Proposed Rules 75109 y@

In issulng this rhle. NRC reccgnizes planning was conceived as a secondary In addition. the Commission the siFnificant responsibilitics assigned but additional measure to be exercised acknowledges the important to the Federal Emergency h!anagernent in the unlikely event that an accident contributions rnade this year by various W

A;cncy (FENIA) by Executive Order would happen. The Commission's official commenters on the state of W;

15143 on July 15.1979. fo coordinate the perspective was severely altered by the emergency planning around nuc! car q

cmergency planning functions of unexpected sequence of events that facilitics, whose views are included as gN cxecutive acencies. In view of FENfA's occurred at Three Mile Island. The part of the basis for these reguations.

new ro!c. NRC agreed on September 11, accident showed c!carly that the The first of these was the report of the

$g 1r9. that FEMA should henceforth chair protection provided by siting and General Accounting Office issued 5

the Federal Interagency Central engincered safety featercs must be coincident with the TMI accident which Coordinating Committee for bolstered by the ability to take explicitly recommended that no new gadiolegical Emergency Response protective measures during the course of nuclear power plants be permitted to 5

planning and Preparedness (FICCC). In an accident.The accident also showed operate "un! css offsite cmcrgency plan.,

>f addition. NRC and FEMA have agreed c!carly that on. site conditions and have bcen concurred in by the NRC." as to exercise joint responsibility for actions, even if they do not cause a way to insure better emergency M

concurring in State emergency response significant off-site radiolepical protection. CAO Report. EMD-70-110.

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plans prior to NRC issuance of op( ratina consequences, will affect the way the "Arcas Around Nuclear Facilities dp hrenses. During the next few months various State cnd local entities react to Should De 11citcr Prepared for N

NRC and FEMA will continue to protect the public from dangers, real or Radiological Emergencies" (March 30, y

reexamine intra-federal relationships imagined, associated with the accident.

1973). In addition, the NRC M

and responsibilitics regarding A conclusion the Commission draws Authorizatica Eill for FY 1SEO (S. 502)

D radiological emergency response from this is that in carrying out its would amend the Atomic Energy Act to 6.t planning. Ilowever, the Commission statutory mandate to protect the public require a concurred in State plan as a g

does not believe that the reexaminat,on health and safety, the Commission must condition of operation. The policy c

i shculd serve as a basis for delay in the be in a position to know that off-site consideration that undcriics this 34 prcposed rule change.

governmental plans have been reviewed provision zould be consistent with the TH At several places in the proposed and found adequate. The Commission Commission's views of the heclth and b

a nendments, the Commission refers to finds that the public can be protected safety significance of cmergency M

'he roles of State and local governments. within the framework of the Atomic planning. One of the Corr. sission's 9

Indeed the main thrust of the proposed Energy Act only if additional attention is liouse Oversi;ht Subcomn ;ttees given to emergency response planning.

dcretoped a comprehensive document SN rule is that prior concurrence in State and local emergency response plans will The Commission recognizes that the oa the status of emergency planning Q

te a condition for licensing and increment of risk involved in operation which recommended that NRC. In a cperation of a nuc! car powerplant.The of reactors over the prescribed times in leadership ccpecity, undertake efforts to 9

Ccmmission recognizes that it cannot the implementatien cf this ru!c does not upgrade its licensecs' crnerg:ncy plans

d. rect any governmental unit to prepare constitu'e an unacceptable risk to the and State and local plans. !!ous'e Report W!

a plan. much less compel its cde quacy.

public health and safety.

No. 90-n 3. " Emergency Planning E

The Commission rece Around U.S. Nuclear Power plants,"

Ej lbwever, the NRC can conditien a propcsal, to view emerg$rizes tbt this

. cease on the existence of adequate ncy planning as 50Q Ccrg.1st Sess. (August 8.1979).

E

' Wh'ile the State and local equivalent to. rather than a secondery

'Ihe Report's recommendation: were to. su, m; and desgn m po%c pmtecton, ssmfic.mt and its undings about tne 4

pvernments have the primary departs from its prior regulatory respons;bi: sty under their coristitutional nced for improved emergency g

pc!!ce powers to protect their pubhc. the appmach to cmergency pictmng. The preparedness lcnd support to the NRC,s g

Ccmm:,ss,on has studied the vnnoes own cfrorts to assure that the pubhc is g.

i Cammission. under authcrity granted to pmpesals cnd belicves that thia course protected. Final y. the President s g

at by the Congress. also has an important responsibility to protect the is the best availab!c chaire. In reacmng Commission en the Acc:dcnt at Three j

tlu,s detcrmination. the Commission is

.%le Island has recently recommended g

public in matters of radiological health and safety. Accordinely, with an gmded by the findings cf its Emergency approved State and local plans as a, Q

understanding of its limitations and with planning Task Force which found the condition for resuming licensing. This g

a sensitivity to the irnportance of all need for miensive effoit by NRC over Commissica s Report and its supporting g

tevels of governments working together, the next few years to up;rade the S'aff Reports on emerpency responses gq Se Commission will commit to seek and regulat ry program m tms area.The and prepareancss are indicative of

.y Commission has a!so endorsed the rnany of tne problems which the NRC

.z apply the necessary resources to make its part in this venture work.

findings of the epa-NRC Joint Task would address in this rule. In this regard Force for policy developre. cat in this the Commissica notes that the already s

Rationale for Change crea. !ap!cmentation of these reports by extensive record made on emergency 4

The proposed rule is predieved on the the NRC in its staff guidance is planning impros ements will be y

Commissien's considered jud;nent in necessary for the NRC to be as cffective supp!cmented by the report of its own W

de aftermath of the accident at Three as possibla in cssisting those Special Inquiry Group and other ongoing 92 Mde Island that safe siting cnd design.

governmental units and those utilitics investigations by any requirements of y;

en;!neered features alona do not responsible for execution of the plans.

the NRC Authc.rization Act. and by the.

M cptimize protection of the pub!!c health The Cc mmission acknowledges the pablic comments solicited by this M

and safety. Defore the accident it was input of over one hundred commenters proposed rule.

4 Sought that adequate siting in to date on the proposal to adopt new The proposed ru!c meets many of the h

accordance with existing staff guidance regulations.The staff evaluation of these concerns discussed in the above T;

coupled with the defense-in-depth comments is incorporated by reference mentioned reports and publications.

approach to design would be the herein as part of the record in this liowever, the Commission notes that the y

primary public protection. Emergency rulemaking proceeding.

proposed rule is considered as an

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4 73170 Fed 2ral Register / Vol. 44, No, :'45 /, Wednesday, December 19,19~9 / Proposed Rules

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interim ypgrade of NRC emergency immediate action. Under the other (g)If the application is fcr an l

pla ming rt.gulations and,in essence, s!ternative (Alternative B), the licensee operating license for a nuc! car Pwar

" clarifies and expands areas that have would be required to shut down the reactor, the applicant shall subnnt i

been perceived to be deficient as a p! ant immediately in this circumstance.

radiological emergency response plans result of past exgeriences. Because the Unless and until an exemption is of State and local governmental entities Ccmmission anticipates that further Franted, the licensee will not be allowed in the United States that are who!!y cr changes in the emergency planning to operate the reactor.

partially within the plume exposure regulatice.s may be proposed as more The NRC contemplates that under pathway Emergency Planning Zone experience is g'ained with implement 2ng Alternative A initial concurrence and (EPZ). as well as the plans of State i

these revised regulations, as the various subsequent withdrawal,if necessary, governments wholly or partially within Three Mdc Island investigations are would be noted in local newspapers.

the ingestion pathway EPZ.8 Cenera!!y, concluded, and as the results become Under Alternative D, public notice of the plume exposure pathway EPZ for ava!!ab!c from efforts in such areas as any initial concurrence or withdrawal of nucl car power reactors shall consist of instrumentation and monitoring and concurrence would be made both in the an area about 10 miles in radius and the generic studies of accident models, these Federal Register and in local ingestion pathway EPZ shall consist of proposed rules may require further newspapers. Notice in the Federal an area about 50 miles in radius. The rnadi'ications. Thus the proposed rule Register and in local newspapers will exact size and conf:guration of the EPZs changes shouM be viewed as a first step also be provided of any required surrounding a particular nuclear power in improving emergency planning.

suspension of operation, any request for reactor shall be determined in relation Pubhcation of these proposed rule an exemption from this requirement, and to the emergency response needs and i

changes in the Federal Register any request that an operating license be capabilities as they are affected by such supersedes and thus eliminates the need exempt from the requirement for local conditions as demography, t

to continue developraent of the proposed concurred-in plans. Public comments topography, land characteristics, acces s i

ra!c change to 10 CFR Part 50, Appendix will be welcomed. If significant interest routes, and local jurisdictional j

E (43 FR 37473). published on August 23, in meetmg with the staffis expressed, boundaries. The plans for the ingestion l

,t 1973. regard ng Emergency Planning the staff may hold pub!!c meetings in the pathway shall focus on such less l

considerations outside the Low vicinity of the site to receive and discuss iramediate actions as are t.ppropriate ta l

Population Zene (LPZ).

comments and to answer questions.

protect the food ingestion pathway.

I The Commissicn is considering According!y,in the discharge of its

2. A new i 50A7 is added. Alternative l

whether construction permits which duties to assure the adequate protectica versions of the first paragraph are have already been issued should be of the public health and safety, the presented.

I reconsidered because of the ernergency Commission has decided to issue planning considerations of this rule. For proposed rules for public comment.The f 50A7 Emergency plans.

piants in operation, NRC teams are now proposed changes to 10 CFR 50.33,50.47,

[ Alternative A:(a) No operating n.ceting with licensees to upgrade and 59.54 apply to nuc! car power license for a nuclear power reactcr wi!!

licensee State ar.d local emerrency reacters only. Ilowever, the proposed be issued unless the emergency plans and implementing procecurcs.

Appendix E to 10 CFR Part 50 app!!cs to response plans submitted by the j

In developing these proposed rule production and utilization facilites in applicant in acccrdance with i 50.33'r) changes, the Comm:ssion has general except as noted in the proposed have been reviewed and concurred in by censidered the puential consequences, Appendix E. These proposals, the NRC.rIn the absence of cne or mera social and economic, as well as safcty, comments, other official reports, and concurred-in plans, the applicant wi'!

of the shutdown of an operating nuclear views expressed at the public have an opportunity to demonstrate to i

power plant. Under both alternatives, workshops will be factored into the final the satisfaction of the Commission that the substantive criteria to be applied in reie, which the NRC now anticipates dcliciencies in the plans are not F~

evaluating whether or not a licensee will be published in early 1930.

significant for the plant in question, that should be a!! owed to continue to Pursuant to the Atomic Energy Act of alternative compensating actions have i

l operate the reactor cre the same.Hus, 1954. as amended, the Energy been or will be taken promptly, or that both alternatives reflect the view that, Reorganization Act of 1974. and section there are other compelling reasons to while emergency planning is important 533 of title 5 of the United States Code, permit operation.] OR for public health and safety, the notice is hereby given that adoption of

[ Alternative B:(a) No operating increment of risk involve in permitt!ng the following amendments to to CFR license for a nuclear power reactor wl11 operatica for a limited time in the Part 50 and Appendix E to 10 CFR Part be issued unless the emergency absence of concu red-in plans may not 50 is contemplated.

response plans submitted by the be undue in every case.

Copics of comraents received on the applicant in accordance with ! 50.333) liowever, the alternative rule changes proposed amendments may be have been reviewed and concurred in ty d;ffer primarily in the course of action examined in the Commission's Public the NRC.2 An applicant may request an that would follow either non-Document Room at 171711 Street. NW.,

exemption from this requirement based concurrence, lack of concurrence, or Washington. DC, and at local Public withdrawal of concurrence in relevant Document Rooms.

'Emmeno riannme Zones (ErZd are discussed State or local emergency plans. Under in NUREGGG. "riannme Basis for the one alternative (Alternative A) an order PART 50--DOMESTIC LICENSING OF

[ Y C 'r$cr$ " N p b r [ s Ys' m to show cause why the licensee should PRCDUCTION AND UTILIZATION of tot water Nucicar rcer riana.-

not shut down the plant may be issued FACILITIES

• Nac starr adance rar the preparation and in this circumsta,nce, but the order to

1. P r graph (g) of 150.33 is tevised to

"*'"' " S's*c"concurr'e*nc'e'S'"rY "'P "

d 1 cal plans leadme to N is coniamed ia shoW Cause Wou.d not be made read as follows:

NUFEG r5hH. " Guide and Checkhst for immediately effective unless the Developrient and Eva!uarmn or state and Loret Commission decided in the particular

! $0.33 contents of app!! cations; general Governrnent Rad.o!cnical Emersency Response cases that the safety risks were information.

Plans in support ot raeJ Nuctear racance

[D,'<"sT3,$," ##" ' **d sufficiently serious to warrant such 4

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_ m m.m.wam- - =

w

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N,.%:*

U y/

ederal Register / Vol. 44, No. 245 / Wednesday, December 19, 1979 / Proposed Rules 75171 y

w--

within 100 days of local government emergency response spon a dernonstratToryby the applicant been concurred in 8 that any dificiencies in the plans are not the effective date of the final plans do not warrant continued NRC ggnificant for the plant in question, that amendments or by January 1,1001, concurrence and such State or local al:ema:ive compensating actions have whichever is sooner, the Commission government fails to correct such de iciencies within 4 months of the date r

been er will be taken promptly, or that will make a determinatica whether the there are other compe!!ing reasons to reactor should be shut down.The of notification of the defects, the reacter reactor need not be shut down if the in question wi!! be shut down. The

[ermit operation. No such operatin';rense wMl be issued unless NRC finds licensee can demonstrate to the licensee may request an exemption from that appropriate protective actions, Commission's satisfaction that the this requirement based upon a including evacuation when necessary.

deficiencies in the plan are not demonstration that any deficiencies in can be taken for any reasonably si;nificant for the plant in question, that the plans are not significant for the plant anticipated population within the plume alternative compensating actions have in question, that alternative e3pesure EpZ.)

been or wi!! be taken promptly, or that compensating actions have been or will (b) Generally, the nlume exposure there are other compe!!!ng reasons for be taken promptly, or that there are p3dway EpZ for m. dear power plants continued cpcration.] OR [ Alternative D: other compelling reasons for continued shall consist of an area about 10 miles in if the plans submitted by the licensee in operation. Ilowever, unless and until radius and the ingestion pathway EpZ accordance with the subsection have this exemption has been grcated by the shall consist of an area r.bcut 50 miles in not been concurred in by NRC within Ccmmission, the plant shall be maintained i' the shutdown condition.]

radius. The exact size and configuration 100 days of the effective date of this n

cf the EPZs surrounding a particular amendment or by January 1,1981, (u) The hcensee of a nuclear power cadear pow er reactor shall be whichever is sooner. the reactor in reactor shall provide for the determined in relation to the emergency que, tion wi;l be shut down until the development, revision, imp!cmentation response needs end capabilities as they concurrences have been obtained. The and maintenance ofits emergency are affected by such local conditions as licensee may request an exemption from preparedness program.To this end, thu de: caraphy, topography, land this requirement based upon a licensee shall provide for an c;cractenstics, access routes, and local emonstration that any deficiencies in independent review ofits emer;;cncy j::isdictional boundaries. The phns for the plans are not significant for the plant preparedness program at least every 12 the ingeshon pathway sha'.I focus on in question, that alternative months by licensee, employees, sxh less irnmediate actions as are compensating actions have been or will centractors, or other persons who have -

ion be taken promptly, or that there are no direct responsibihty for appropnate to protect the foed ingest.

other cornpe!!ing reasons for continued implementation of the emergency F30WdY-

3. Section 50.54 is amended by addm.g operaticn. liowever, unless and until preparedness program.The review shall include a review and audit of licensee faur new paragraphs. (s). (t). (u) and (v).

this exemption has been granted by the Ntemative passages for paragraphs (s)

Commission, the plant shall be drills, exercises, capabilities, and acd (t) are prosided:

maintained in the shutdown condition.]

pmcedures.The results of the review and audit, along with recommendations 150.54 Conctlans of Ucan:es.

(A!!crnative A: (t) If, after le] days f r impr vements, sha!! be documented.

fo!!owin;; the effective date of these (s) Each licensee who is authorized to emendments or January 1,1981,

'han

,bpt a -

P P

1 pcssess and/or operate a nuclear power s,hichever is sooner, and during the at the plant for :nspection for a period of rea: tor shall submit within CD days of operating hcence p od of a nut! car 7

the effective date of this amendment the power reactor the Commission

.%;'t$in 100 days after the effective raiological emergency response plans determines that the appropriate Stat date of the final rules or by January 1, of State and local governmental entities and local government emergency 1981, whichever is sooner, each licensee la the United States that are wholly or response plans do not warrant who is authorized to possess and/or partially witnin the plume exposure continued NRC concurrence and such operate a production or utilization paiway EPZ, as well as the plans of State or local government fails to correct facility shall have plans for coping with State governments wholly or partially such deficiencies within 4 months of the emergencies which meet the wiSin the ingestion pathway EPZ.8 date of notification of the defects, the requirements of Appendix E of this Generady, the p!ume exposure pathway Commission will make a deterraination Chapter EPZ for nuclear power reactors shall whether the reactor shall be shut down 4.10 CFR Part 50 Appendix E,is censist of an are i about 10 miles in until the plan is submitted and has again amended as follows:

ratus and the ingestion pathway EPZ received NRC review and concurrence.

shallconsist of an area about 50 miles in The reactor need not be shut down if the radius.The exact size and configuration licensee can demonstrate to the Appendix E-Emergency Planning and cf the EPZs for a particular nuclear Commission's satisfaction that the Preparedness for Production and 1;tilization Facilitics' pcwer reattor shall be determined in deficiencies in the plan are not tt!ation to the emergency response significant for the plant in question, that I. Intmduction teeds and capabilities as they are alternative compensating actions have Each applicant for a construction permit is affected by such Iccal conditions as been or will be taken promptly, or that required by i so.31(al to include in its demegraphy, topography, and land there are other compelling reasons for characteristics, access routes, and local continued operation.] OR

'Nnc staff has devetored three regulatory gudes:

):risdictional boundaries. The plans for

'( Alternative U: (t) If, after 180 days U01?Fmyncy Manning far Nucieer Power the ingestion pathway shall focus on following the effective date of these

[,'"c','[,MM'."fn,$'"j"8 ((n$'y"n'$,i yp 8'Eh less immediate actions as are amendments or after January 1,1981, C le Facat+s and Plan's 12 censed L'noer 10 CFR erpropriate to protect the food ingestion whichever is sooner, and during the Parts so and ro": and NIEG-Octo.

• Draft 74* hay. (Alternative A:If the operating license period of a nuclear En erency Level Action Cutdr.hnes for Nuclear EfCpriate State and local government power reactor, the Commission

," th*[3 '((,

['p" p,f,"$f'[*"

"Sency response plans have not determines that the appropriate State or Footnotes continued on next pace mw i

M

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.m. m _

.m

..._ m

r 75172 Federal Register / Vol. 41. No. 245 / Wednesday, December 19. 1979 / Proposed Rules prel;rninary'sdety analysis report a offsite property and the expected response, of an ernergency to protect public health and a

discusion of prehminary plans fcr coping in the event of an emergency of offsite safety mthin the Emergency Plannmg Zoncs with eme"rgencies. Each apphcant for an agencies] OR (EPZs).']

D.As.

operatiqg hcense is required by i 50.34(b) tc (Alternative B: C. Protectise measure to be IV. Ccc!cct ofErcryency Thns Th+

include in its final safety anal) sis report taken in the event of an accident within the the rr.

plans for coping with emergencies.

site boundary and within each EpZ to protect The app!icant's emergency plans shall g,y This append.s establishes minimum health and safety; procedures by which these contain, but not necessarily be limited to, the descr.

reqJirements [C% emergency plans [Cr use In measures are to be Carried out (eg, in the fo!!awmg e!cments; organizatien for copmg that c attaining a state of emergency preparedness.

case of an evacuation, who authorizes the with radiation emergencies, assessment.

tn. nt-These plans shall be descr; bed in the evacuation, how the public is to be not fied action, activation of cmergency organization.

pm.

prehm. nary safety analysis report and and instructed, how the evacuation is to be notificatien prccedures, emergency facihtirs ando-submitted as a part of the final safety carried out); and the expected response,in and equipment, training, maintaining emerc ant. lysis report. T he potenbal radiological the esent of an emersency, of offsite emergency preparedness, and recove y.The

,, c7, hazards to the public associat(d with the agencicsl:

apphcant shall also provide an analys:s of

,, t e c.

operation of research and test reactors are D. Features of the facility to be provided the time required to esacuate various sectors when.

considcrab!y less than those involved with for oncite emergency first aid and and distances within the plume exposure consa nuclear paw cr reactor. Consequently, the size decontamination. and for ernergency pathway EPZ for transient and permanent bouns of the EPZs for Research and Test reactors transportation of onsite individua s to offsite populations.

prever and the dwee to which compliance with the treatment facilities:

A. Organization a ct.c n requircrums of this section and sections !!.

E. Provisions to be made for emc gency

. to th cond:-

!!!. IV and V is necessary will be determined treatment at offsite facihties ofindividuals o$ogfca erner enc cs I described onsite on a case-by. case basis using Regulatory injured as a result of licensed activities:

includm def'nitions of authorities emerr ra Guide ? G as a s!andard for acceptance. State F.Presisions for a training pregram for res?ons bi;ities and. duties of indi[iduals and er and local government crnergency response employees of the hcensee, including those assed to hcmee s emergency andic pians, which may inc!ude the plans of offsite who are assigned spec:fic authority an3 organization, and the means of notification c,f appm surport organizations, shall be submitted resp ns ility m the evnt of an emergency, such individuals in the event of an reV2ew with the ap;!icant's emermcy plans-and for other persons not ernployees of the, ernergency. Specifically, the following shall 80V8f r

11 The Preliminary Safety Analysis Repcrt licensee whose assistance may be necded in be included; C. Act:

lic Preliminary Safety Analysis Report the event of a radiological emergency:

1. A description of the normalplant

-The(

shall contain sufficient infc.rmation to ensure G. Features of the facdity to be provided to operating organization.

cond' tr.e compatibility of proposed emeyency enme tne capa ity for actuatin ons!!e

2. A desenption of the onsite emergcncy activa plans both for onsite areas and the EPZs with protective measures and the capabdity for response organization with a detaded the tot facihty desinn features, site lavout, and site facity rmtry m crder to mitigate the discussion of; desc location with respect to such c'cnsiderations c arequencca of an accident or,if

a. Authorities, responsibi!ities and duties cf alert '

as access routes. sur-ound.ng popation appropriate, to continue operation:

the individucl(s) who will take charge durb?

each c',

disti:butions. and land use for the Emergency R A preHminary anahsn wntch proj.ects an emergency:

g*4 p;anning Zones 8 (EPZs).

the time end means to be emp!oyed in the

b. Plant staff emergency assignments;

1. [,5 D As a minicnum. the foi owirg items shall be n tification of State and local governments

c. Authcrities, responsibihties, and dates dercribed; and the pubhc m the event of an emergency.

of an onsite emergency ccordinator who s J.!

A. Onsite and offsite orginizations for A prehminary analysis of the time required to be in charge of the exchange ofinfo mat::n E'"%

{N ceping with emergencies, and the means for evacuate various sectors and distances with effsite authorities responsible for

'Id" nr.nfication. in the es ent of an cmergency. of within the plume exposure pathw;ay EPZ for cocrdinating and impelementing offs.te persons assi:;ned to the emer;ency transient and permanent popu!at2ons.

emergency measures.

y.7],.

orpnizatiens:

1/L The Fina/ Safety Ana/pis Report

3. A description of thelicensee headquarters personnel that wdl be sent to D. Contacts and arrancements made and of a me c ntain the emergency plan:, y}eport shall.th The Final Safety Analysis l the pl ant site to provide augmcntation c,f the documented with local. State, and Federal c ted f.:

opmg wi cnsite emergency organization.

govermncntal agencies wi'h respons.bihty for coping with emergencies. includ.cg emergencies. Tha plans shall be an

4. Ident:fication by position, of person:

D. Notd idenhfication of the principal agencies.

expression of the overall concept of within the licensee organization who wi.i te 1, Ad:

[ Alternatis e A: C. Protecta e rneasures to operation. which desertbe the essential responsible for making offsite dose not fyin be taken in the event of an accident within elements of advance planning that hase been projections and a description of how these the site boundary and within each EPZ to considered and the provisions that have been projections will be rnade and the results local, s, ei;encic protect health and safety; correctis e rnade to cope with emergency situations. The tranmitted to State and local authoritie s.

and for

• measures to prevent damage to ons:te and plans shall incorporate information about the NRC. FEMA and other appropriate teuur[

crnergency response roles of supporting governrnental entities.

tha'd be organizations and offsite agencies. That

5. Identification, by pc:;ition and functcn.

include :

rootnotes continued from lut nze I W 34 and this A;;enda for ccpmg wim info-mation shall be sufficient to provide of other employees of the licensee with eff; cia!s.

e rcr2encies. Copies of the gmdes are avahbte at assurance of coordination among the speci.il quahfications for coping with b erre-the Commas:on's Public Document Roc:n. trt711 supporting groups and between them and the emergency conditions which may arise. Oier

2. PE 5:reet. NW. Washington. D C. oni Cepies of licensee.

persons with special qualifications, such as

)early c ndes may be purchased from the Gournment

[ Alternative A:The plans submitted must contu!! ants, who are not emp!oyees of the p!ume e.

Pnnting On:ce. taformation on curmt pnces may include a description of the elements set out licensee and who may be called upon fer e.,

be obtamed by wnbrg the LJ S. Nudeer Regalatory in Section IV to an extent sufficient to assistance for short or long.tcrm p ss I

S\\,ls demonstrate that the plans proside emergencics shall also be identified.%e

-[

L*' a n\\

n

• The sue of the EPZs for a nuc! car power plant reasonable as:urance that appropriate special quahfications of these persons shall l their ca.,

sha'l be determmed in relaton to the emergency measures can and will be taken in the event be descr: bed.

preetta response needs and capab.ht:es as they are affected of an cmergency to protect public health and

6. A description of the tocal offsite scryices cceg3,,

b) sah local cond.hons as democaphy.

safety and mimrnize damage to property to be provided in support of the licen3ce te!w ork toperaphy land charactenshes. access routes. and within the Emergency Plannirg Zones emergency organization.

ct u 'a---

locol pnsdictional boundancs. Generat!y the plume (EPZs).'] OR

7. Identif.catica of and expected assistance

1. AA

,',"hP'(([,

[ Alternative B:He plans submitted must from appropriate State, local. and Federal

% t$e 3'""'

n g

radme and the i. gestion pthway EPZ an area include a description of the elements set out agencies with responsibilities for ccpir; w;th der +q about 50 m.fes in radius. ErZe are d.scussed in in Section IV to an extent sufficient to emergcncies.

NUREG4m The size of the FTZ's fcr non rower demonstrate that the plans proside

8. Identi'ication of the State and/orlocal ett to es reactors shall be detenn.ned en a case-by-case reasonable assurance that appropriate officials responrible for planning for.

ww.eg,'

baus.

measures can and will be taken in the event ordering. notificatien of. and contro!!ir.g m@u'y A D7(D

^D

- w n

._a

.-- _.w _:w

m Federal Redster / Vol. 44. No. 245 / Wednesday, December 13. 1979 / Proposed Rules 73173

,ppropriate prowt.T e ac*ioes. including

• o the public within the plume exposure

a. D: rectors or coordinators of the plant evacs,atics w hen necessary.

pathway Emergency Plannmg Zone. It is the emercency organization.

apphcant's responsibihty to ensure that such

b. Personnel responsib!e for accident S. Assessment Actions means esist, regard:ess of who implements assessment including control room shift The mear s to be presided far determinin4 this requirement.

personnel,

c. Radiological man;toring teams,

\\

E. Emergency Facilities and Equipment

d. Fire control teams [ fire brigades).

t.

r cas fr oaci e t rials desertbed includmg emergency actwn lesels Provisions shall be made and described for

e. Repair and demage control teams.

that are to be used as criteria for determm:ng emer;:ency facihties and equipment.

f.First a d and rescue teams.

R. Local services personnel, e g local Civil the need for notification and participation of includmg:

bcal and State agencies and the Gnnmission

1. Equipment at the site for personnel Defense. local law enforcement personnel, and other Federal acencies, and the rnonitoring; and local news media persons.

c:nergncy action levels that are to be used Equipment for detm.ining the magnitude

h. Medical suppcrt personnel.

as ct;teria alon2 with apprornate of and for continuously assessing the release g, ggc,n3,,.s headquarters support e eteorologicalinformatwn for deterrnm, ing of radioactac raatern:s to the environment; personnel.

when protectne measures should be

3. I acihties and supphes at the site for

). Secunty personnel.

decontamination of onsite individuals:

The plan shall describe provisions for the considered within the outside the site boundary to protect health and safety and

4. Facihties and rnedical supplies at the site ccnduct of yearly drilis and exercises to test for appropriate emer;ency f.rst aid treatment; the adenuacy of timing cnd content of preyent damne to property.The emer;;ency

5. Arrangements for the services of a mplementing procedures and methods, to a: tion les els shall be based on in plant cenitians and instrument stion in addition to physician and other rnedical personnel test emergency epipment an3 cns.te and effsite monitorin;t These quahfied to handfe radiaticn emergencies:

communication netw orks, and to ensure that emergency action les els shall be discussed

6. Arran;;ements fcr transportation of f

injured or contaminated individuals from the emerpncy organpation pesonnel are famihar with their dat.es. Such provisions l c.d agreed upon by the applicant and State site to treatment facihties outside the site shall specifically mclude participanon by anj local gas ernmental authorities and approsed by N! C. They shall also be boundary:

offsite personnel as described abcs e as well

7. Arranrements for treatment of as other State and local governmental reuewed with the State and local inda iduals iniured in support of hcensed agencies.The pian shall a!:,o desenbe i

gavernments! a uthonties on an annual basis.

activities on the site at treatraent facdities provisions for a joint exercise involving the C Activation of Emergency Organization outside the site boundarv:

Fedcral. State, and local response lle entire st ectrum of emerrency

8. One onsite techmcai support center and organizations.The scope of such an exercise cend.tmns which mvoh e the alertmg or one near-site emergncy operation center should test as much of the emer;cncy plans.

activation of progressively larger segments of from which effectis e direction can be given as is reasonably achievab!e wehout mvo?ving the total emer;yncy orpnization shall be and effective control can be exercised during full pub lic participation. Defmita e desenbed. The communicatwn steps taken to an cmergency; performance critena shall be established for n'e-t er actisate emer;ency personnel under

9. At least one onsite and one offsite each class of emer:ency shut te described.

comrnunicatwns system. includmg redendant n!!!cvels of participation to ensure an E ergency actien leve!s (based not cnty on power sources. Thrs M1 mdude the objective esa!uation.This joint Fedc al.

communication arringrnents for State, and local exercise shall be:

cesite and ofNte ridiation monitorin,'a emergencies. incluin; t&s and a!!crnates

1. For presently cperating plants. initially cfermation but also on readm:s frorn cun:ber of sensors that indicate a pctcntial for those in charga at both ends of the within one year of tne effective date of this communication hnis and the primary and a nendment and once every (Alternative A:

emergency such as the pressure in ccatamment and the resper.se of the backup means of commumcation. % here three years] or [Alternath e 3: f.ve years]

c nsistent wnh function of the posernmental thereafter.

Emen;ency Care Cco:m:: Ss stem) for caticatica of offsne adenbes shalbe agency, these arrangements w Ul include:

3. For a plant for which an operating

8. Provision for communicat;ons with license is issued af ter the effective date of descnbed.1he existence but not the details.

c ntiguous State / local governments within this amendment. imtia!!y within ene year of cf a message authentication scheme shall be the plume exposure pathway Emergency the issuance of the operating license and ccted for such agencies.

Planning Zone. Such communications shall be once escry ( Alternative A: three yearsj or D. Notication Procedures tested monthly.

[ Alternative B: five years l thereafter.

1. Administnine and physical means for

b. Provision for communications with All trainin-nrousions shall provide for cotdying. and agreements reached witn.

Federal emergency response orgamrations.

formal criti

_s in order to evaluate the local. State, and Federal offaiais and Such communications s3 stems shall be tested emergency plan's effectiveness and to ccrrect agencies for the early warnmg of the pub!!c annually.

weak areas throu:;h feedback wah emphasis

c. Provtsien for communications between on schedules. lcsson plans. practical training, and for pubhc es acuation or other protective the nuclear facihty. State and/or local and periodic examinations.

c:easures. should thr y Leceme nes.e3u:ry.

shall be described. This description shall emergency operations centers, and field G. Maintaining Emergency Preparedness assessment teams. Such communications include identihcation of the pnncipal efficia!s. by title and agencies, for the systems shall be tested annually.

Provisions to be employed to ensure that the emergency plan. its implementing Emergency Plannma Zones '(EPZs).

F. Training pr cedares and emergency equipment and

2. Provisions shall be descnbed for the 8

d 8tmn8 supphes are maintained up to date shall be learly dissemination to the pubhc within the of employees and exercismg. by periodic descnbed^

p;eme exposure pathway EPZ of basic drills, of radiation emereency plans to ensure

~

R &csey ectrgency plannmg informa: on such as the that employees of the hccnsee are fam:bar pessibihty of nuclear accidents, the poteatial with their specific emergency response Criteria to be used to determine when to bman health effects of such accidents and duties, and (?) the participation in the the extent possib!c. following an accident, their causes. rnethods of notificatwn. and the training and dnlls by other persons whose reentry of the facihty is appropriate or when Trotectne actions planned if an accident assistance may be needed in the esent of a operation should be contmued.

occurs. as w e:I as a hstma oflocal broadcast radiation emergency sha!! be desenbed. This V. Implementing ProccJures network that willlye used for dissemmation shallinclude a description of specialized of information during an emergency.

initial training and penodic re rainmg No less than 180 days prior to schedufed

3. Administratne and phpical means, and programs to be prosided to each of the issuance of an operatmg hcense.10 copies the time required, shall be desenbed for followmg categories of emergency personnel:

each of the apphcant's detaded implementing procedures for its emergency plan shall be alterting and providmg prompt instructions a public wi&in the ptee cuposure pathway T.p2 submitted to NEC lleadquarters and to the

'It is espected that the capahMy wdl Le wehen 15 mmutes of the rmnhcation by the bcensee appropriate NRC Regional Office: Provided Pended to essentially complete a:ertmg of the of local and State of tcasts.

that,in cases where the operatmg hcense is D9[D

• D ~9' Ed

. k, ]

A

] N N

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I

.,s 75174 Federal Register / Vol. 44, No. 245 / Wednesday, December 19, 1979 / Proposed Rules i

sch;d32d to be issed less than 100 days rca nmTHEn INFCnMATION CONTACT:

Board was aware tht much of the

.

• e.f ter the effective date of this rule, such Benton F.hiassell(Office of Regulations terminology of the regulation is commen imp!cmenting procedures shall be submitted and Emergency Planning). Economic and !cgally reccgnized through its U"

Regu!atory Administration, Room 7112, consistency with the Uniform

'heefec d

c co I nce un er t

200051 Street, N.W., Washmgton, D.C.

Commercial Code. Although language 150.54[v) with the resised Appendix E.

Lcensees who are authorized to operate a 20101 (202) 254-7203.

improvements were made to achieve nuclear rpwcr facihty shall subrnit to copics issued in Washington, D.C., Decernbcr 13, brevity and clarity, care was taken not to alter legal concepts through stylistic each of tre licensee's emergency plan

1979, implementing procedures to NRC F* Scott Bush' change.

IIcaJau-rtcrs end to the appropriate NRC is The Board notes that the revised Assistant Admm.. trator. Reguictions cnd Regional Ofince. As neces ary to maintain materiag was drafte3 to con 7orm them up to date thereafter,10 copics each of Emergency P!cnning. Economic Regulatory any changes to these imp!cmentmg Adm;nistrc!/on.

generally with the new part of Regulation J, Subpart C (Automated procedures shall be submitted to NRC pv. oce. mew rm is-t7.mo ss am)

Clearing flouse Items) which the Board licadquarters and to the same NRC Regional estuaa coot e44 41-u

__ recently approved for public comment Office within 30 days of such changes.

(Sec.1ct Pub. L 83-703. 08 Stat. 9 la (42 (44 FR 67095). Only minor editorial U.S C. :20t h Sec. 201 as amended. Pub. L FEDERAL RESERVE SYSTEL1 changes will be required to conform a 93-433. 63 Stat.1242. Pub. L 9 4-73. 89 Stat.

final version of Subpart C with the 413[4:U.S.C. 5311).)

12 CFR Part 210 revised Subparts A and D.

Dated it Washington. D.C. this 13th day of This notice is published pursuant to December tr9.

[ Reg. J; Docket No. R-02001 section 552(b) of Title 5, United States Fct the Nuclear Regulatory Commission.

Collection of Checks and Other items Code, nnd i 202.2(a) of the rules of Samuel J. Chi'k, and Transfer of Funds procedure of the Board of Governors.

Secret ry cf the Cammission.

The proposalis inade under the An:NCY: Ucard of Covernors of the p1t ooe. n-ms r.iw 12-is-a s es aml authority of sections 11 and to of the Federal Reserve System.

Federal Reserve Act (12 U.S.C. 24S (j),

causa cc:;r rswei-u

____ ACTION: Proposed rules.

(o)), which authorize the Board to

~

promulgate rules governing the transfers su:#.:MnY:Uy th.is act. ion the Board DEPARTf.!ENT OF ENERGY of funds through Federal Reserve Banks.

proposts to clarify and simpl;fy its To aid in the consideration of this Econernic Regulatcry Adm!nistrction regulations on the collection of checks and other items and for wire transfers of material by the Board, in,terested persons arc invited to su T.it re!cvant 10 CFR Part $70 funds. It is not intended that any data, views, comments, or arguments.

substantive changes be made in the To implement Hs proposal, ec Ecan.

ICc:ket No. ERA-R-79-54]

duties and responsibilitics that are set

, }

I CF t

ss f b! v Standby Gasoline Rationing Plan forth in these regulatory provisions.

cATE: Comments must be received on or ActN Y: Economic Regulatory Administration Department of Energy.

beferc February 15,1930.

IRG II Accasss: Comments, which should refer PART 210-COLLECTION OF CHECMG AcT!ON: Notice of Additional Public t Docket No. R-02CS may be mailed i AND OTHER ITEMS AND WIRE I fearing.

Theodore E. Allison, Sccietary, Board of TRANSFER 3 O? FUNDS sumunY:On December 7,1979, the Governors of the Federal Reserve Eccnomic Regulatcry Administration System 20th Strect and Constitution Subpart A-Couection of Checks and Ct.".:r r._

items (ERA) of the Department of Energy Avenue, NW., Washington, D.C. 20531, (DOE) issued a notice of proposed or delivered to Rcom B-2223 between see.

rulemaking and public hearings to 8:45 a.m. and 5:15 p.m. Comments 210.1 Authority, pu pose, and scope.

receive ccmments on its proposed received may also be inspected at Room 210.2 Definitions.

Standby Casoline Rationing Plan (44 FR B-1122 between 8:45 a.m. and 5:15 p.m.,

210.3 General prods!cns.

210.4 Sendtrg items to Reserve Banks.

70799. December 10,1979). Public except as provided in section 201.G(a) of 2:0.5 Sender's agreement: recovery by hearings are schedu!cd for Boston, MA, the Doard's Rules Regarding Availability Sen Francisco, CA, Chicago, IL, New of Information (12 CFR 201.0(a)).

RcQe D 23g ranties, and liabi?ity cf Orleans, LA and Washington. DC.

ron FUnTHErt INFORE1ATION CONTACT:

Reserve Bank.

The purpose of this notice is to Lcc S. Adams, Senior Attorney (202/

210.7 Presenting items for payment.

schedule a additional public hearing on 452-3594), Legal Division, Daard of 210.8 Presenting ncncash items for the proposed Standby Gasoline Governors of the Federal Reserve acceptance.

i

10.9 Payment.

Rationing Plan in Seattle, WA.

System, Washington, D.C. 20551.

210.10 Time schedute and availability cf DATEE: I! caring: January 3 and 4,1900.

SUPFLEf.tCNTARY INFORf.tATion:As part credits for cash items.

beginning at 9:30 a.ra. Requests to speak cfits Regulatory Improvement Project,

10.11 Availability of proceeds of noncash l

raust be received by December 28,1979.

the Board has reviewed the regulatory items: time schedule.

ADDrtESS ES:Ilcaring location: New framework for the collection of checks 210.1: Return of cash items.

Federal Building. 915 2nd Avenue, South and otheritems and for wire transfers of 210.13 Chargeback of unpaid items.

Auditorium (4 th Floor), Seattle, WA funds that are set forth in Subparts A 210.14 Extension of time lin..ts.

98174.

and B Sf Regulation J.The Board has Subpart D-Wire Transfer of Funds Requests to speak should be determined that, while substantive 210 :5 Authority, purpose, and scope.

addressed to: Department of Energy, changes in the regulation were not

10.:s Det nitions.

Attn: Janet Marcan,1992 Federal required,it was desirab!c to redraft the 210.27 General provisions.

Building,915 2nd Avenue, Seattle, WA regulation to clarify and simplify the 210.:3 Media for transfer items and 98174.

language. In redrafting Regulation J. the requests.

[

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p* *f cg'o UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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WASHINGTON, D, C. 20555

%*Si November 29, 1979 ALL POWER REACTOR LICENSEES Gentlemen:

This letter, which is being sent to all licensees authorized to operate a nuclear pwer reactor and to all applicants for a license to operate a power reactor (FSAR docketed), is a request for infomation regarding estimates for evacuation of various areas around nuclear power reactors. The requested infomation is in addition to that requested by the October 10, 1979 letter to all power reactor licensees from Darrell G. Eisenhut, Acting Director, Division of Operating Reactors, Office of Nuclear Reactor Regulation.

Although evacuation time estimates are expected to be prepared in the course of the upgrading of the state of emergency preparedness as specified in the October 10, 1979 letter, submission of these estimates to the NRC is being requested on an accelerated time scale so that the NRC can identify those instances in which unusual evacuation constraints exist and special planning measures should be considered.

In some cases of extreme difficulty where a large population is at risk, special facility modifications may also be appropriate.

The requested infomation will also enable the NRC to be responsive to a recommendation from the Environment, Energy and Natural Resources Subccamittee of the House Comittee on Government Operations.

The infomation requested in the enclosure should be submitted no later than January 31, 1980.

The October 10, 1979 letter indicated that efforts to develop a model plan were continuing.

It now appears that the model plan will not be completed on a schedule which will be of use in developing upgraded plans for the requestea January 1,1980 submittal. The upgraded plan development should therefore proceed on a site-specific basis.

Sincerely, s

hw Brian K. Grimes, Director Emergency Preparedness Task Group Of fice of Nuclear Reactor Regulation

Enclosure:

Request for Evacuation Time Estimates cc w/ enclosure:

Service List i

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REQUEST FOR EVACUATION TIME ESTIMATES (AFTER NOTIFICATION)

FOR AREAS NEAR NUCLEAR POWER PLANTS

Background

Prior to recent NRC requests that means for prompt notification to the public be installed around each nuclear power plant site, a significant component of evacuation time estimates was the time required to notify the public of a need for evacuation.

Studies of actual evacuations that have taken place generally do not distinguish between the time required for notification, the time required to implement the evacgtion, and the time required to confirm that an evacuation has taken place.-

The estimates for time required for evacuations now requested relate primarily to the time to implement an evacuation as opposed to the time required for notification. These erMaates may be based on previous local experiences (e.g., chemical spills or floods) or may be based on studies related to population density, local geography and road capacities. No standard method for making such estimates is identified for use at this time.

The basis for the method chosen should be described in the response.

As an independent check on the evacuation time estimates, agreement with or comments on the time estimates made should be obtained from the principal local officials responsible for carrying out such evacuations.

Such agreement should be documented or the areas of disagree-ment indicated in the submittal.

The format given below is appropriate for reporting to the NRC estimates of the time required to implement evacuation of areas near nuclear power plants.

These estimates, are to be made for the primary purpose of making available, to those of ficials who would make evacuation decisions in an emergency situation, knowledge of the time required to complete one of the protective action options (evacuation) available for a particular potentially affected

'~ ~ ~~

segment of the population.

A second purpose of these estimates is to identify to all concerned those instances in which unusual evacuation constraints exist and that special planning measures should be considered.

In some cases of extreme difficulty where a large population is at risk, special f acility modifications may also be considered.

Given a decision to evacuate rather than shelter in an actual event, fewer or more sectors or different distances than given in the reporting format might be evacuated should this be the chosen protective action. For example, three 22-1/2* sectors might be initially evacuated in a downwind direction (the sector containing the plume and an adjacent sector on each side), followed by the evacuation of other sectors as a precautionary measure.

~1/Hans, J. M., Jr., and T. C. Sell,1974 Evacuation Risks - An Evaluation, U. S. Environmental Protection Agency, National Environmental Research Center, Las Vegas, EPA-520/6-74-002.

^

Format for_?cportine Information The areas for which evacuation estimates are required must encompass the entire area within a circle of about 10 miles radius, and have outer coundaries corresponding to the plume exposure EPZ. These areas are as follows:

Distance Area 2 miles two 180* sectors 5 miles four 90* sectors about 10 miles four 90* sectors EstiSates for the outer sectors should assume that the inner adjacent sectors

&re being evacuated simultaneously. To the exent practical, the sector boundaries should not divide densely populated areas. Where a direction corresponding to the edges of areas for which estimates have been made is thought not to be adequately represanted by the time estimates for adjacent areas, an additional area should be defined and a separate estimate made for this case.

Tne format for submittal should incluoe both a table and a figure (overlaid on a map) which each give the information requested in items 1 and 2 below.

Additional material may be provided in associated text.

Reauired Information 1.

Two estimates are requested in each of the areas defined in item 1 for a general evacuation of the population (not including special facilities).

A best estimate is required and an adverse weather estimate is required for movement of the population.

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2.

The total time required to evacuate special facilities (e.g., hospitals) within each area must be specified (best estimate and adverse weather).

3.

The time required for confirmation of evacuation should be indicated.

Confirmation times may consider special instructions to the public (e.g.,

tyir.g a hankerchief to a door or gate to indicate the occupant has left the premises).

4.

Where plans and prompt notification systems have not been put in place for areas out te about 10 miles, estimates of the times required to evacuate until such measures are in place for the plume expnsure emergency planning zone (EPZ) should also be given. Notification times greater than 15 minutes should be included in the evacuation times and footnoted to indicate the notification time.

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Where special evacuation problems are identified (e.g., in high 5.

population density areas), specify alternative protective actions, such as sheltering, which would reduce exposures and the effectiveness of these measures.

A short background document should be submitted giving the methods 6.

used to make the estimates and the assumptions made including the routes and methods of transportation used.

This document should also note the agreement or areas of disagreement with principal local officials regarding these estimates.

December 10, 1979

• 0 Mr. Harold Denton Director Office of Nucicar Reactor Regulations U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Denton,

I have been reviewing the Draft Environmental Statement and Final Environmental Statement for Limerick Units 16 2, U. S. NRC Regulatory Guide 4.7, the Report of the Siting Policy Task Force - NUREG-0625 and the Report of the President's l

Comminion on the Accident at Three Mile Island. There are several areas that are very disturbing to me - both tha 1970 and 1980 projected populations in the surrounding Limerick, the response of the Department of Environmental Resources regarding the seismology of the area surrounding Limerick - in the Final Environmental Statement, and several responses regarding the water supply and diversion of water from the Delaware River.

I have read of the recent testimony of Mr. Robert Ryan regarding the siting of the Indian Point plant in New York, the Zion plant in Illinois and also the concern regarding six other plants in the United States. Limerick is number 2

three en this list and echoes concerns that I have had since the accident at Three Mile Island since I live in close proximity to this site.

It is a densely populated area within a radius of 10 miles of Limerick and is mainly a suburban-rural area with roads that are not much more than macadamized potholed, cowpaths.

I have recently received a reply to an inquiry that was made on my behalf by Senator Richard Schweiker.

It is from Mr. Lee V. Gossick of the NRC.

Enclosed is a copy of this letter and a chart that I have prepared of the population density for this area from the DES on Limerick. There is one point that is disturbing to me - the population density guide from NUREG-0625, Section 2.1.2.7

" Population Density - Practice" and Mr. Gossick's comment, "These criteria have not been retroactively applied to previously approved sites such as Limerick."

The LPZ for Limerick is 1.28 miles and the nearest population center, Pottstown, p

Pa., is 1.7 miles. In addition to Pottstown with 25,500 population (1970) North Coventry Township with a current population of 7,600 lies parallel to Pottstown, separated only by the Schuylkill River. The LPZ at TMI is stated as 2 miles in the " Report of the President's Commission to Investigate the Accident at Three Mile Island." Why is the LPZ for Limerick smaller when the meg.aatt capacity is greater than TMI? Theae figures do not include transient population, people who would be at their places of employment in the area. According to Mr. Gossick's letter there were additional safety features incorporated in the Limerick plant to " mitigate consequences of a design basis accident." The simple fact is that if any accident would occur, design basis or other, that would result in large amounts of radiation being released, the number of people that would have to be notified and evacuated are extremely large.

The roads in this area are not conducive to a safe and effective evacuation.

J.

Nuclear accidents can occur at any time of the year including times when these roads are nearly impassable after a severe snowstorm.

It is stated in NUREG-0625 that a site which exceeds these guidelincs (500/ square mile) "can nevertheless be selected and approved." If these guidelines 4

are not met and an alternative site is not availabic why is not another source of, s

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fir. Jiarold Denton.

fuel recommended for the site?

It is stated in the DES on Limerick on page 10,8 that, "The above disadvantages notwithstanding, the staff feels that a coal-fired plant is an alternative that can be considered." Why was this not strongly recor. mended at that time? It seems to me that retroactive application of population guidelines should be a serious consideration at Limerick.

Another area of concern to me is the response of the Department of Environmental Resources regarding the seismology of the area around Limerick.

In the DES it is stated that "the nearest approach of a fault trace to the site is 1300 feet west; is 350 feet".

In NUREG-0625 it is stated in a footnote 4

it's vertical displacement (page 28) surface faulting is " identified as a current basis for rejection of sites."

I would refer you to pages !!-94 through H-98 of the Final Environmental statement for the responae of the DER regarding the seismology of the area.

I do understand, however, that the U. S. Geological Survey will be doing some studies on this matter.

The third significant point is the water supply to cool this plant.

I would like to refer you specifically to the response of Dr. Ruth Patrick, Chairman of the Department of Limnology of the Acadeny of Natural Science in Philadelphia.

This can be found on page 11-74 through !!-78 in the Final Statement. There are

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also several other comments regarding the diversion of water f rom the Delaware River. The Delaware River Basin Commission has stated recently that the Schuylkill hiver is one they are most concerned about us far as quality and quantity at low flow periods. Ilow can Philadelphia Electric Company taking these huge quantities of water frcm the river and evaporating 35,000,000 gallons per day be justified when a fossil-fueled plant wc.uld use a significantly lesser amount?

In conclusion, there is a recorr.ci f ation in the repert of the accident at TMI to site nuclear power plants in less densely populated areas. Limerick is overall less than 507. complete - Unit 1 is 547. and Unit 2 is 357. completed.

I under::tand that if the plant were modified to use coal as a source of fuel, instead of uranium, some parts of the plant could be used and some money would be lost in the construction thus far completed. This money can eventually be replaced, but the large num'ers of people whose lives would be disrupted and endangered if a o

serioua accident occurred, cannot b2 discounted and this fact must be given grave consideration.

I would also like to point out an inaccuracy in Mr. Cossick's letter, Pottstown, g/

rennsylvaats is located northwest of the reactors, not southwest as Mr. Gonsick stated.

I will appreciate your response to my concerns and questions. Thank you very 4-much.

Sincerely, 9 A % (l e. 5 / $<

Marlene G. Seidts cc: vGerator Richard Schweiker M.

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VMr. John Ahearne o 1W A, Pc vMr. Robert Ryan VMr. Brian K. Grimes j g n (, 0

/Cov. Thornburg/f

Enclosure:

As stated

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UNITED STATES NUCLEAR REGULATORY COMMISSION e

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D 1 E gg Docket flos. 50-352 and 50-353 The Honorable Richard S. Schweiker United States Senate Washington, D. C. 20510

Dear Senator Schweiker:

This letter is in reply to your letter of August 17, 1979, requesting our consideration of a letter from Marlene G. Seidts regarding the siting of the Limerick Generating Station, a nuclear power plant in Montgomery County, Pennsylvania.

Mrs. Seidts' letter of August 10, 1979, refers to a 1962 Atomic Energy Ccmmission Technical Information Document (TID) 14844 that established population center distances on the basis of 1000 MW reactors of the type then being proposed.

The criteria of TID-14844, which considered only the engineered safeguard of a low-leakage containment, were not applied to the 1970 staff review of the Limerick construction permit application.

Additional engineered safety features were incorporated in the design of Limerick to mitigate the consequences of a design basis accident.

In accordance with the provisions of the Ccmmission's Reactor Site Criteria, 10 CFR Part 100, this had the effect of permitting a significantly lesser minimum distance to a population center.

Over the years, it has been the general policy of the fluclear Regulatory Commission (fiRC) to encourage power reactor siting in low population areas. To that end, the Commission's regulations on reactor siting criteria, 10 CFR Part 100, require that every power reactor have: an exclusion area immediately surrounding the reactor which is under the control of the applicant; a low population zone, outside the exclusion area, where appropriate protective measures could be taken to protect the public in the event of a serious accident; a popu'ation center distance such that the nearest densely populated center, of about 25,000 or more persons, be located at a distance no closer than one and one-third times the outer radius of the low population zone.

With regard to Limerick 1 & 2, the minimum exclusion area distance is 2500 feet, the low population zone outer radius is 1.28 miles, and the nearest population center, Pottstown, Pa. (1970 population, approximately 26,000 perscns)., is located about 1.7 miles southwest of the reactors.

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'The Honorable Richard S. Schweiker.

As also required by Part 100, the radiological consequences of a postulated serious accident involving a major fission product release within the containment must be shown to be within the guideline values (25 rem to the whole body and 300 rem to the thyroid gland) to an individual assumed to be located at the exclusion area boundary for a two hour period, and to an individual assumed to be located at the outer boundary of the low population zone for a 30 day period.

Both the licensee and the Commission's staff analyzed such events and concluded that the combination of plant safety features and site characteristics were such that the consequences of such an event would be within the regulatory guidelines.

In addition, the Commission's staff reviews both current and projected population in the vicinity of the site, and continually develops criteria for use in its reviews dealing with population density. These criteria, which are not part of the Ccmmission regulatiors but which do offer guidance on staff review practices, have evolved with time. At the time (1970) that Limerick was under review for a construction permit, the Commission's staff used the guideline that the cumulative population in the vicinity of a proposed site should generally not exceed the highest values for previously approved and licensed sites.

Population levels for the Limerick site were generally found to meet this criterion.

The Ccmmission staff has, over the years, given increased attention to population distribution criteria for siting newer plants.

In October 1975, (more ti.an one year after the issuance of the Construction Permit for Limerick), the f1RC staff published Regulatory Guide 4.7, " General Site Suitability Criteria for fluclear Power Stations." (Copy enclosed.) We believe it is this guide that contains the " advisory" criteria referred to by Mrs. Seidts.

In the context of environmental reviews, this guide contains the following language relative to population in the vicinity of a proposed site:

"If the population density, including weighted transient population, projected at the time of initial operation of a nuclear power station exceeds 500 persons per square mile averaged over any radial distance out to 30 miles (cumulative population at a distance divided by the area at that distance), or the projected population density over the lifetime of the facility exceeds 1,000 persons per square mile averaged over any radial distance out to 30 miles, special attention should be given to the con-sideration of alternative sites with lower population densities. As indicated by the staff criteria, a site which exceeds these population density guidelin'es can nevertheless be selected and approved, if, on balar.;e, it offers significant advantages as compared to available and alternative sites by considering all the environmental, safety and econcmic aspects of the selected site and the alternative sites."

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The Honorable Richard S. Schweiker These criteria have not been retroactively applied to previously approved sites such as Limerick.

With regard to schools (elementary or otherwise) in close proximity to reactor sites, there is no established criterion that prohibits the existence of schools, residences, or industrial complexes that have no adverse effects on the safe operation of the reactors cr produce a hazard to the public, within or just outside of the Low Population Zone. The elementary school that Mrs. Seidts is concerned about is approximately 1.35 miles from the nearest Limerick reactor and is just outside the outer boundary of the Low Population Zone.

Part 100 describes the " Low Population Zone" as the area immediately surrounding the exclusion area which contains residents, the total number and density of which are such that there is a reasonable probability that appropriate protective measures could be taken in their behalf in the event of a serious accident.

These guides do not specify a permissible population density or total population within this zone, because the situation may vary frcm case to Whether a specific number of people can, for example, be evacuated case.

from a specific area or instructed to take shelter, on a timely basis, will depend on many factors such as location, number and size of highways, scope and extent of advance planning, and actual distribution of residents within the area.

It was determined that the Low Population Zone for the Limerick site met this criterion.

Before the Limerick reactors are licensed for operation, they will be subject to re-review by the flRC. This review will address our concerns for the protection of public health and safety and the environment. The operator, Philadelphia Electric Company, will be required to work with the State of Pennsylvania to develop an emergency plan for the plant vicinity.

This plan will be reviewed by the Commission before the plant can begin operation.

In conjunction with Mrs. Seidts' concms, you may be interested to know that before the TMI 9 accident, the Commission had requested a thorough review and examination of its siting policy, and in that regard had requested a staff task fore to give its recommendations regarding any needed changes in the Commission's siting criteria. The " Report of the Siting Policy Task Force" fluREG-0625, was published in August, and a copy of it is enclosed.

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Sincerely, f

j R' n,f Leh T~~Gossick Executive Director for Operations

Enclosures:

1.

10 CFR Part 100 2.

RG 4.7 3.

fiUREG 0625 4.

Memo 8/17/79 to f1RC from Sen. Schweiker

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