ML19290C586
| ML19290C586 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 12/13/1979 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| Shared Package | |
| ML19290C542 | List: |
| References | |
| NUDOCS 8001220120 | |
| Download: ML19290C586 (38) | |
Text
Enclosure No. 1 NUCLEAR REGULATORY COMMISSION
[10 CFR Part 502 EMERGENCY PLANNING AGENCY:
U.S. Nuclear Regulatory Commission ACTION:
Proposed Rule
SUMMARY
The Nuclear Regulatory Commission, after considering the public record available concerning licensee, State and local government emergency preparedness, and the need to enhance protection of the public health and safety, is proposing to amend its regulations to provide an interim upgrade of NRC emergency planning regulations.
In a few areas of the proposed amendments, the Commission has identified two alternatives which it is considering.
In each instance both alternatives are presented in the following summary of the prooosec changes and in the specific proposed rule changes presented in this notice.
The final rule will not necessarily incorporate all cf the first alternatives or all of the second alternatives.
That is, in seme instances tne first alternative may be adocted and in others, the second alternative may be adooted.
Further alternatives may be adopted as a result of consideration of public comments.
In one alternative (Alternative A), the procosed rule change would not automatically recuire susoension of operations for lack of concurrence in appropriate State and local government emergency response plans on the date specified in the rule, even if the Commission by that date has not yet determined whether the reactor should be allowed to continue to operate.
It would:
1787 321 80 012 20 l 2L(p) 1
L7590-01]
1.
Require NAC concurrence in the appropriate State and local government emergency response plans prior to operating license issuance, unless the applicant can demonstrate to the satisfaction of the Commission that ceficiencies in the plans are not significant for the nuclear power plant in question, that alternative comcensating actions have been or will be taken premptly, or tnat there are other compelling reasons for license issuance.
2.
For nuclear po.er reactors alreacy licensec to operate, if appropriate State anc local emergency response plans nave not receivec NRC concurr-ence witnin 150 days after tne effective care of this amencment er by January 1,1951, wnichever is socner, require the Commission to cetermine wnether to require the licensee to snut down tne reactor.
If at that time the Commission fines that the licensee has demonstrated that tne ceficiencies in the plans are not significant for the plant in question, that alternative compensating actions have ceen or will be taken promotly, or tnat tnere are other compelling reasons for continued operation, then the licensee may continue coeration.
If at inat time tne Commission cannot make sucn a finding, then the Ccmmission will orcer the licensee to show cause why the plant should not be snut cown.
In cases of serious ceficiencies, tne order to show cause will be mace immeciately effective anc the licensee woulc be required to shut cc-n tne reactor.
P 3.
For nuclear pc er reactors alreacy license: to coerate, if aporopriate State anc local emergency res;ense ;1ans ce net warrant continued NRC 1787 322 2
L/ovu-uij 4
concurrence and the State or locality do not correct the deficiencies within 4 months of notification by the NRC of withdrawal of its con-currence, require tne Commission to determine whether to require the licensee to shut down the reactor.
Shutdown may not be required if the Commission finds that the licensee has demonstrated that the deficiencies in the plan are not significant for the plant in question, that alternative compensating actions have been or will be taken promptly, or that there are other compelling reasons for continued operation.
If at this time the Commission cannot make such a finding, then the Commission will order the licensee to show cause wny the plant should not be shut down.
In cases of serious deficiencies, the order to show cause will be made immediately effective and the licensee would be required to shut down the reactor.
In the other alternative (Alternative B), the proposeo rule change would automatically require nuclear power plant shutdown for lack of con-currence in a:propriate State and local government emergency response plans on the date specified in the rule unless an exemption is granted by that date.
It would:
1.
Require NRC concurrence in the accropriate State and local government emergency response plans prior to operating license issuance.
- However, the Ccmmissicn can grant an exemption frcm this requirement if the applicant can demonstrate to the satisf action of the Commission that deficiencies in the plans ere net significant for the plant in question, 1787 323 3
Liasv v2; 4
that alternative compensating actions have been or will be taken promptly, or that taere are other compelling reasons for license issuance.
No such operating license will be issued unless NRC finds that appropriete protective actions, including evacuation when necessary, can be taken for any reasonably anticipated population within the plume exposure EPZ.
2.
For nuclear power reactors already licensed to operate, require a licensee to shut down a reactor immediately if appropriate State or local eme gency response plans have not received NRC concurrence within 180 days of the effective date of the final amendments or by January 1,1981, whichever is sooner.
However, the Commission may grant an exemption from this requirement if the licensee can demon-strate to the satisfaction of the Commission that the deficiencies in the plans are not significant for the plant in question, that alternative compensating actions have been or will be taken promptly, or that there are other compelling reasons for continued operation.
If there is no concurrence, and the plant is shut down, then it must remain shut down until such an exemption is granted or until concurrence is obtained.
3.
For nuclear power reactors already licensed to operate, require a licenst e to shut down a reactor if appropriate State or local emer-gency response plans do not warrant continued NRC concurrence and the State or locality does not correct the deficiencies within 4 months of notification-by the NRC of withdrawal of its concurrence.
However, the Commission can grant an exemption to this reouirement 1787 324 4
[7590-01]
if the licensee can cemonstrate to the satisfaction of the Commission that the deficiencies in the plan are not significant for the plant in question, that alternative compensating actions have been or will be taken promptly, or that there are other compelling reasons for continued operation.
If there is no concurrence and the plant is shut down, then it must remain shut down until such an exemption is granted or until concurrence is regained.
In both alternatives the proposed rule would:
4.
Require that emergency planning considerations be extended to "Emer-gency Planning Zones."
5.
Require tnat applicants' and licensees' detailed emergency planning implementing procedures be submitted for NRC review.
6.
Clarify and expand 10 CFR Part 50, Appendix E, " Emergency Plans for Production and Utilization Facilities."
DATES:
Comments should be submitted on or before (60 days after publication).
ADDRESSES:
Interested persons are invited to submit written comments and suggestions on the proposed rule changes and/or the supporting value/
impact analysis to the Secretary of the Commission, U.S. Nuclear Regula-tory Commission, Washington, D.C. 20555, Attention:
Docketing and Service Branch.
Copies of the value/ impact analysis and of comments received by the Commission may be examined in the Commission's Public Document Room 1787 525 5
Lisaw vAJ at 1717 H Street, v,i., Washington, D.C. and at local Public Document Rooms.
Single copies of the value/im;act analysis, related regulatory guides, and the NRC staf" analysis of the puclic comments received on the Advance Notice of Proposec Rulemaking may be cotained on request.
FOR FURTHER INFORMATION CCNTACT:
Mr. Michael T. Jamgochian, Office of Standards Development, U.S. Nuclear Regulatory Commission, Washington, D. C.
20555 (Telepnone:
301-c"3-5966).
SUPPLEMENTARY INFORMATICN:
In June 1979, the Nuclear Regulatory Commission began a fermal reconsiceration of the role of emergency planning in assuring the continuec protection of tne public health and safety in areas around nuclear power facilities.
The Commission had begun this reconsideration in recogniticn of the need for more effective emergency planning and in response to repcrts issuec by responsible offices of government and its Congressional oversight committees.
By memorancum catec July 31, 1979, the Commission requested tnat the NRC staff ancertake expecitec rulemaking on the subject of State, local, and licensee emergency resconse plans.
The proposed rulemaking described in tnis notice responcs to that recuest, and has been prepared on an expedite: tasis.
Consecuently, consicerations related to the work-ability of the proposed rule may have been overlooked and significant impacts to NR, a: licants, licensees, and State and local governments may not have been identified.
Therefore, the NRC particularly seeks comments acdressed to these points and intends to nold workshoes prior j
to preparing a "inal rule to (a) present the proposed rule changes to State and local governments', utilities, and other interested parties and i
3 1787 326 5
I
t m u-u1J (b) obtain comments concerning the costs, impacts, and practicality of the proposed rule.
The Nuclear Regulatory Ccmmission is considering the adoption of amendments to its regulation, " Domestic Licensing of Procuction and Utiliza-tion Facilities," 10 CFR Part 50, that would require that emergency response planning considerations be extended to Emergency Planning Zones (ciscussed in NUREG-0396, EPA 520/1-78-016, " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants").
Both the Commission and EPA have formally encorsed the concepts in that EPA /NRC Report, 44 Fed. Rec. 61123 (October 28, 1979).
In addition, the Nuclear Regulatory Commission is considering revising 10 CFR Part 50, Appendix E, " Emergency Plans for Production and Utilization Facilities," in orcer to clarify, expand, and uograde the Commission's emergency planning regulations.1 Prior to the conclusion of this rulemaking proceeding, the Commission will give special attention to emergency planning matters, including the need for concurred-in plans, on a case-by-case basis in accordance with the modified acjudicatory procedures of 10 CFR Part 2, Appendix B.
Under that Appendix, no new license, construction permit, or limited work authori:ation may be issued without Commission consideration of issues such as this.
Both versions ITwo NRC staff guidance documents are related to this proposed rule change.
" Draft Emergency Action Level Guidelines for Nuclear Power Plants," NUREG-0610 was published for interim use and comment on September 19, 1979.
It is expected that a final version of the action level guicelines, based on the public comments received, will be issued in early 1980.
In addition, in early 1980 upgraded and revisea acceptance criteria for evaluating emergency preparedness plans will be issued for comment and may be included in the Commission's regu-lations.
244 Fed. Rec. 65049 (November 9, 1979).
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\\
s L/ovu-UAJ of the proposed amencments call for State and local government emergency response plans to be submitted to and concurred in by the NRC as a condi-tion of operating license issuance.
Under one alternative being considered, the proposed rule would re-quire a detemination on continued operation of plants where relevant State and local emergency response plans have not received NRC concurrence.
Shutdown of a reactor would not follow automatically in every case.
Under the other alternative proposal, shutdown of the reactor would be required automatically where the appropriate State and local emergency response plans have not received NRC concurrence within the prescribed time periods.
However, the Commission could grant an exemption to this requirement if the licensee can demonstrate to the satisfaction of the Commission that the deficiencies in the plan are not significant for the plant in question, that alternative compensating actions have been or will be taken promptly, or that there are otner compelling reasons.
If there is no concurrence and the plant is shut down, then the plant must remain shut down until sucn an exemption is granted or until concurrence is obtained.
The NRC presently requires that power reactor licensees and appli-cants plan for radiological emergencies within their plant sites and make arrangements with State and local organizations to respond to accidents that might have consequences beyond the site boundary.
In this way, offsite emergency response planning has been related to the nuclear licensing process.
To aid State and local governments in the development and implementa-tion of acecuate emergency response plans, the NRC, in conjunction with several other Feceral agencies, has attempted, on a cooperative and voluntary basis, to provice for training and instruction of State anc local government 1787 528 e
[7590-01]
personnel and to establish criteria to guide the preparation of emergency response plans.
However, in the past, the NRC has not made NRC concurrence in State and local emergency response plans a condition of operation for a nuclear power plant; the proposed rule would do so, as explained above.
In issuing this rule, NRC recognizes the significant responsibilities assigned to the Federal Emergency Management Agency (FEMA) by Executive Order 12148 on July 15, 1979, to coordinate the emergency planning functions of executive agencies.
In view of FEMA's new role, NRC agreed on September 11, lE79, that FEMA should henceforth chair the Federal Interagency Central Cocrdinating Committee for Radiological Emergency Response Planning and Preparecness (FICCC).
In addition, NRC and FEMA have agreed to exercise joint responsibility for concurring in State emergency response plans prior to NRC issuance of operating licenses.
During the next few months NRC and FEMA vill continue to reexamine intra-federal relationships and responsibilities regarding radiological emergency response planning.
However, the Cortmission does not believe that the reexamination should serve as a Lasis for deli.y in the proposed rule change.
At several pla as in the proposed amendments, the Commission refers to the roles of State and local governments.
Indeed the main thrust of the proposed rule is that prior concurrence in State and local emergency response plans will be a condition for licensing and operation of a nuclear NRC staff guidance for the preparation and evaluation of State and local emergency response plans leading to NRC concurrence is contained in NUREG 75/111, " Guide and Checklist for Development and Evaluation of State and Local Government Radiciogical Emergency Response Plans in Support of Fixed Nuclear Facilities" (December 1, 1974) and Supplement 1 thereto dated March 15, 1977.
The adequacy of this guidance is being reevaluated by the. staff and the Commission will consider codi-fication of the upgraded criteria in 1980.
1787 329 9
L/090-01) power plant.
The Commission recognizes that it cannot direct any govern-mental unit to prepare a plan, much less compel its adequacy.
- However, the NRC can condition a license on the existence of adequate plans.
While the State and local governments have the primary responsibil-ity under their constitutional police powers to protect their public, the Commission, under authority granted to it by the Congress, also has an important responsibility to protect the public in matters of radio-logical health and safety.
Accordingly, with an understanding of its limitations and with a sensitivity to the importance of all levels of governments working together, the Commission will commit to seek and apply the necessary resources to make its part in this venture work.
Rationale 'er Chance The proposed rule is predicated on the Conmission's consicered judgment in the aftermath of the accident at Three Mile Island tnat safe siting and design-engineered features alone do not optimite protection of the public health and safety.
Before the accicent it was thougnt that adequate siting in accordance witn existing staff guidance couplec witn the defense-in-depth approach to design would be the primary public pro-tection.
Emergency planning was conceived as a secondary but adcitional measure to be exercised in the unlikely event that an accident would happen.
The Commission's perspective was severely altered by the unexpected secuence of events that occurred at Three Mile Island.
The accident showed clearly that the protection provided oy siting and engineered safety features
- Ust be bolstered by the ability to take protective measures during tne
~
course of an accident.
The acticent also showed clearly that on-site conditions and actions, even if they do not cause sign %ficant of'-site e,--.
1787 330 lo
Lissu uAj 9
radiological consequences, will affect the way the various State and local entities react to protect the public from dangers, real or imagined, asso-A conclusion the Commission draws from this ciated with the accident.
is that in carrying out its statutory mandate to protect the public health and safety, the Commission must be in a position to know that off-site governmental plans have been reviewed and found adequate.
The Commission finds that the public can be protected within the framework of the Atomic Energy Act only if additional attention is given to emergency response planning.
The Commission recognizes that the increment of risk involved in operation of reactors over the prescribed times in the implementation of this rule does not constitute an unacceptable risk to the public health and safety.
The Commission recognizes that this proposal, to view emergency plan-ning as equivalent to, rather than as secondary to, siting and design in public protection, departs from its prior regulatory approach to emergency planning.
The Commission has studied the various proposals and believes that this course is the best available choice.
In reaching this deter-mination, the Commission is guided by the findings of its Emergency Planning Task Force which found the need for intensive effort by NRC over the next few years to upgrade the regulatory program in this area.
The Commission has also endorsed the findings of the EPA-NRC Joint Task Force for policy development in this area.
Implementation of these reports by the NRC in its staff guidance is necessary for the NRC to be as effective as possible in assisting those governmental units and those utilities responsible for execution of the plans.
The Commission acknowledges the input of over one hundred commenters to date on the proposal to adopt new regulations.
The staff evaluation I.
/
11 7]17 111
L/cuu-u1J of these comments is incorporated by refsrence herein as part of the record in this rulemaking proceeding.
In addition, the Commission acknowledges the important contributions made this year by various official commenters on the state of emergency planning around nuclear facilities, whose views are included as part of the basis for these regulations.
The first of these was the report of the General Accounting Office issued coincident with the TMI accident which explicitly recommended that no new nuclear power plants be permitted to operate "unless offsite emergency plans have been concurred in by the NRC," as a way to insure better emergency protection.
GAO Report, EMD-78-110, " Areas Around Nuclear Facilities Should Be Better Prepared for Radiological Emergencies" (March 30,1979).
In additio1, the NRC Authorizatien Bill for FY 1980 (5.562) would amend the Atom;c Energy Act to require a concurred-in State plan as a condition of operation.
The policy consideration that underlies this provision would be consistent with the Commission's views of the health and safety significance of emer-gency planning.
One of the Commission's House Oversight Subcommittees developed a comprehensive document on the status of emergency planning which recommended that NRC, in a leadership capacity, undertake efforts to upgrade its licensees' emergency plans and State and local plans.
House Report No.96-413, " Emergency Planning Around U.S. Nuclear Power Plants," 96th Cong,, 1st Sess. (August 8, 1979).
The Report's recommenca-tions were significant and its findings about the need for improved emer-gency preparedness lend support to the NRC's own efforts to assure that the public is protected.
Finally, the President's Commission on the Accident at Three Mile Island has recently recommended approved State and local plans as a condition for resuming licensing.
This Commission's
\\
L787 332
Lessu-vij Report and its supporting Staff Recorts on emergency responses and prepared-ness are indicative of many of the problems which the NRC would address in this rule.
In this regard the Commission notes that the already extensive record made on emergency planning improvements will be supplemented by the report of its own Special Inquiry Group and other ongoing investigations, by any requirements of the NRC Authorization Act, and by the public comments solicited by this proposed rule.
The proposed rule meets many of the concerns discusset in the above mentioned reports and publications.
However, the Commission notes that the proposed rule is considered as an interim upgrade of NRC emergency planning regulations and, in essence, clarifies and expands areas that have been perceived to be deficient 'as a result of past experiences.
Because the Commission anticipates that further changes in the emergency planning regulations may be proposed as more experience is gained with implementing these revised regulations, as the various Three Mile Island investigations are concluded, and as the results become available from efforts in sucn areas as instrumentation and monitoring and generic studies of accident mocels, these proposed rules may require further modifications.
Thus the proposed rule changes should be viewed as a first step in improving emergency planning.
Publication of these proposed rule changes in the Feceral Recister supersedes and thus eliminates the need to continue development of the proposed rule change to 10 CFR Part 50, Appendix E (43 Fed. Rec. 37473),
published on August 23, 1978, regarding Emergency Planning considerations outside the Low Population Zone (LPZ).
The Commission is cons 4dering whether construction permits which have already been issued should be reconsiderec because of the emergency 1787 333
t<ssu v4; planning considerations of this rule.
For plants in operation, NRC teams are now meeting with licensees to upgrade licensee, State and local emer-gency plans and implementing procedures.
In developing these proposed rule changes, the Commission has con-sidered the potential consequences, social and economic, as well as safety, of the shutdown of an operating nuclear power plant.
Under both alter-natives, the substantive criteria to be applied in evaluating whether or not a licensee should be allowed to continue to cperate the reactor are the same.
Thus, both alternatives reflect the view that, while emergency planning is important for public health and safety, the increment of risk involved in permitting operation for a limited time in the absence of concurred-in plans may not be undue in every case.
However, the alternative rule changes differ primarily in the course of action that would follow either non-concurrence, lack of concurrence, or withdrawal of concurrence in relevant State or local emergency plans.
Under one alternative (Alternative A) an order to show cause why the licensee should not shut down the plant may be issued in this circumstance, but the order to show cause would not be made immeciately effective unless the Commission decided in the particular cases that the safety risks were sufficiently serious to warrant such immediate action.
Under the other alternative (Alternative B), the licensee would be required to shut down the plant immediately in this circumstance.
Unless and until an exemption is granted, the licensee will not be allowed to operate the reactor.
The NRC contemplates that under Alternative A initial concurrence and subsequent withdrawal, if necessary, would be noted in local newspacers.
Under Alternative B, public notice of any initial concurrence or withdrawal of concurrence would be maae both in the Federal Repister and in local 14 1787 334
6,,sw was newspapers.
Notice in the Federal Register and in local newspacers will also be provided of any required suspension of operation, any request for an exemption from this requirement, anc any request that an operating license be exempt from the requirement for concurred-in plans.
Public comments will be welcomed.
If significant interest in meeting with the staff is expressed, the staff may hold public meetings in the vicinity of the site to receive and discuss comments and to answer questions.
Accordingly, in the discharge of its duties to assure the adequate protection of the public health and safety, the Commission has deciced to issue proposed rules for public comment.
The proposed cnanges to 10 CFR SS 50.33, 50.47, and 50.54 apply to nuclear power reactors only.
However, the proposed Appendix E to 10 CFR Part 50 applies to production and utili:ation facilities in general except as noted in the proposed Appendix E.
These proposals, comments, other official reports, and views expressec at the public workshops will be factored into the final rule, which the NRC now anticipates will be published in early 1980.
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorgani:ation Act of 1974, and section 553 of title 5 of the United States Code, notice is hereby given that adoption of the following amendments to 10 CFR Part 50 and Appendix E to 10 CFR Part 50 is contemelated.
Copies of comments received on the proposed amendments may be examined in the Commission's Public Document Room at 1717 H Street, NW., Washington, DC, and at local Public Document Rooms.
1787 335 5
PART 50 - OCMESTIC LICENSING OF PRODUCTION AhD UTILIZATICN FACILITIES 1.
Paragra;h (g) of Se:tien 50.33 is revisec to read as fcilows:
5 50.33 Contents of acclications: ceneral information.
n a
e a
n (g)
If the application is for an cperating license for a nuclear pc er reacter, the applicant shall submit radiological emergency response plans of State and local governmental entities in the United States that are wholly cr partially within the plume ex00sure pathway Emergency Planning Zone (EPZ), as well as the plans of State governments wholly or partially within the ingestion path-ay EPZ.I Generally, the plume exposure pathway EPZ for nuclear pc-er reacters snali consist of an area about 10 miles in radius and the ing, tion patn-ay EPZ snail consist of an area about 50 miles in racius.
The exa:t si:e and configuration of the EPZs surrounc-ing a par-icular nuclea oc er react: snail te determined in relation
- the emergency res onse nee:s anc caca ilities as they are affected by su:n lccal ::r.citiens as cen:gra:ny, te ogra:ny, lanc characteristics, access routes, an: iccal juriscietional bouncaries.
The plans for the ingestion pain'ay shall focus on such less immediate actions as are appro-priate to protect the food ingestion pathway.
Emergency Planning Zenes (EPIs) are discussec in NUREG-0396, " Planning Eas's for the Devele: ment cf State anc Local Government Radiological Emergency Rescense Plans in Su;;0-t of Lign: nater Nuclear Power Plants."
1787 336
2.
A new section 50.47 is added.
Alternative versions of the first paragraph are presented.
S 50.47 Emergency olans.
[ ALTERNATIVE A No operating license for a nuclear power reactor will be issued unless the emergency response plans submitted by the applicant in accordance 9
with 5 50.33(g) have been reviewed and concurred in by the NRC.'
In the absence of one or more concurred-in plans, the applicant will have an coportunity to cemonstrate to the satisfaction of the Commissicn that ceficiencies in the plans are not significant for the plant in question, that alternative compensating actions havE been or will be taken promptly, or that there are other compelling reasons to permit operation.] OR
[ ALTERNATIVE B No operating license for a nuclear power reactor will be issued unless tne emergency response plans sucmitted by the applicant in accordance witn 5 50.33(g) have oeen reviewed and concurred in by the NRC.
An appli-cant may request an exemption from this requirement based upon a cemonstra-tion by the aonlicant that any deficiencies in the plans are not significant for the plant in cuestion, that alternative compensating actions have been or will be taken promptly, or that there are other compelling reasons WRC staff guidance for the preparation and evaluation of State and local emergency resonse plans leading to NRC concurrence is containec in HUREG 75/111, " Guide anc Checklist for Development and Evaluation of State and Local Government Radiciogical Emergency Response Plans in Support of Fixed Nuclear Facilities" (December 1, 1974) and Supole-ment 1 thereto ested March-15, 1977.
1787 337 1,
gswww wag to permit operation.
No such operating license will be issued unless NRC finds that appropriate protective actions, including evacuation when necessary, can be taken for any reasonably anticippted population within the plume exposure EPZ.]
Generally, the plume exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles in radius and the ingestion pathway EPZ shall consist of an area about 50 miles in radius.
The ekact size and configuration of the EPZs surrouncing a particular nuclear power reactor shall be determined in relation to the emergency response needs and capa-bilities as they are affected by such local conditions as demography, topography, land characteristics, access routes, and local juriscictional boundaries.
The plans for the ingestion pathway shall focus on such less immediate actions as are accropriate to protect the food ingestion pathway.
3.
Section 50.54 is amenced by adcing four new paragraphs, (s), (t),
(u) and (v).
Alternative passages for sucsections (s) and (t) are provicec:
$ 50.54 Concitions of licenses.
=
=
(s) Each licensee who is authorizec to possess anc/or operate a nuclear power reactor shall submit within 60 days of the effective date of this amencment the raciological emergency response plans of State anc local governmental entities in the United States that are wnclly or partially within the plume exposure patnway EPZ, as well as the plans of State governments wholly or partially within the ingestion pathway EFZ.
Generally, the plume exposure pathway EPZ for nuclear oc*er reactors shall Emergency Planning Zones (EPZs) are ciscussed in NUREG-0396. " Planning Basis for the Development of State anc Local Government Raciological E.re--
gency Response Plans in Supoort of Lignt Water Nuclear Power Plants."
,o
^
1787 338
consist of an area about 10 miles in radius and the ingestion pathway EPZ shall consist of an area about 50 miles in radius.
The exact size and configuration of the EPZs for a particular nuclear power reactor shall be determined in relation to the emergency response needs and capabilities as they are affected by such local conditions as demography, topography, and land characteristics, access routes, and local jurisdictional boundaries.
The plans for the ingestion pathway shall focus on such less immediate actions as are appropriate to protect the food ingestion pathway.
[ ALTER-NATIVE A:
If the appropriate State and local government emergency re-sponse plans have not been concurred in within 180 days of the effective cate of the final amendments or by January 1,1981, whichever is sooner, the Commission will make a determination whether the reactor should be shut down.
The reactor need not be shut down if the licensee can demon-strate to the Commission's satisfaction that the deficiencies in the plan are not significant for the plant in cuestion, that alternative compensating actions have been or will be taken promptly, or that there are other com-peiling reasons for continued operation.] OR [ ALTERNATIVE B:
If the plans submitted by the licensee in accordance with the subsection have not been concurred in by NRC within 180 days of the effective date of this amenc-ment or by January 1,1981, whichever is sooner, the reactor in question will be shut cown until the concurrences have been obtained.
The licensee may reouest an exemption from this requirement based upon a cemonstration that any deficiencies in the plans are not significant for the plant in NRC staff guidance for the preparation and evaluation c f State and local emergency resonse plans leading to NRC concurrency. is centained in NUREG 75/111, " Guide and Checklist for Develocment and Evaluation of State and Local Government Radiological Emergency Response Plans in Support of Fixec Nuclear Facilities" (Decemoer 1,1974) and Supple-ment 1 thereto cated March 15, 1977.
1787 339 1g
question, that alternative compensating actions have been or will be taken promptly, or that there are other compelling reasons for continued operation.
However, unless and until this exemption has been granted by the Commission, the plant shall be maintained in the shutdown condition.]
[ ALTERNATIVE A (t) If, after 180 days following the effective date of these amend-ments or January 1, 1981, whichever is sooner, and during the operating license period of a nuclear power reactor the Commission determines that the appropriate State and local government emergency response plans do not warrant continued NRC concurrence and such State or local government fails to correct such deficiencies within 4 months of the date of notifica-tion of the defects, the Commission will make a determination whether the reactor shall be shut down until the plan is sub_mitted and has again received NRC review and concurrence.
The reactor need not be shut down if the licensee can demonstrate to the Commission's satisfaction that the deficiencies in the plan are not significant for the plant in question, that alternative compensating actions nave been or will be taken promptly, or that there are other compelling reasons for continued operation.] OR
[ ALTERNATIVE B (t)
If, after 180 days following the effective date of these amend-ments or after-January 1, 1981, whichever is sooner, ano during the operat-ing license period cf a nuclear power reactor, the Commission cetermines that the apprcpriate State or local government emergency response plans do not warrant continued FRC concurrence and such State or local government fails to correct such deficiencies within 4 months of the cate <
- notifi-cation of the defects, the reacto-in cuestion will be shut cown.
The 2
787 340
6....
licensee may request an exemption from this requirement based upon a demon-stration that any ceficiencies in the plans are not significant for the plant in question, that alternative compensating actions have been or will be taken promptly, or that there are other compelling reasons for continued operation.
However, unless and until this exemption has been granted by the Ccmmission, the plant shall be maintained in the shutdown condition.]
(u) The licensee of a nuclear power reactor shall provide for the development, revision, implementation and maintenance of its emergency preparedness program.
To this end, the licensee shall provide for an independent review of its emergency preparedness program at least every 12 months by licensee, employees, contractors, or other persons who have no direct responsibility for implementation of the emergency preparedness program.
The review shall include a review and audit of licensee drills, exercises, cacacilities, and procedures.
The results of the review and audit, along with recommencations for improvements, snall be documented, recorted to tne licensee's corporate and plant management, and kept avail-able at the plant for inspection for a period of five years.
(v) Within 180 days after the effective date of the final rules or by January 1, 1981, whichever is sooner, each licensee who is authorized to possess anc/or ocerate a production or utilization facility shall have plans for coping with emergencies which meet the requirements of Appen-cix E of this Chacter.
1787 341 21
4, 10 CFR Part 50, Appendix E, is amended as follows:
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APPENDIX E--EMERGENCY PLANNING AND PREPAREDNESS FOR PRODUCTION AND UTILIZATION FACILITIES 1 I.
Introduction Each applicant for a construction permit is required by 5, 50.34(a) to include in its preliminary safety analysis report a discussion of preliminary plans for coping with emergencies.
Each applicant for an operating license is required by 6 50.34(b) to include in its final safety analysis report plans for coping with emergencies.
This appendix establishes minimum requirements for emergency plans for use in attaining a state of emergency preparedness.
These plans shall be described in the preliminary safety analysis report and submitted as a part of the final safety analysis report.
The potential raciological hazards to the public associated with the operation of research and test reactors are considerably less than those involved with nuclear power reactor.
Consequently, the size of the EPZs for Research anc Test reactors and the degree to which compliance with the requirements of this section 1NRC staff has developed three regulatory guides:
1.101, " Emergency Planning for Nuclear Power Plants," 2.6, " Emergency Planning for Research Reactors," and 3.42, " Emergency Planning in Fuel Cycle Facilities and Plants Licensed Under 10 CFR Parts 50 and 70"; and NUREG-0610. " Draft Emergency Level Action Guidelines for Nuclear Power Plants" (September 1979) to help applicants establish adequate plans equired pursuant to S 50.34 anc this Appendix for coping with emer-gencies.
Copies of the guides are available at the Commission's Puclic Document Room, 1717 H Street, NW., Washington, D.C.,
20555.
Copies of guices may be purchasec from the Government Printing Office.
Information on current prices may be obtained by writing the U.S.
Nuclear Regulatory Commission, Wasnington, D.C. 20555, Attention:
Publications Sales Manager.
22 178J7 342
and sections II, III, IV and V is necessary will be determined on a case-by-case basis using Regulatory Guide 2.6 as a standard for acceptance.
State and local government emergency response plans, which may include the plans of offsite support organizations, shall be submitted with the applicant's emergency plans.
II.
The Preliminary Safety Analysis Report The Preliminary Sa'ety Analysis Report shall contain sufficient information to ensure the compatibility of proposed emergency plans both for onsite areas and the EPZs with facility cesign features, site layout, and site location witn respect to such considerations as access routes, surrounding population distributions, and land use for the Emergency Planning Zones 2 (EPZs).
As a minimum, the following items shall be described:
A.
Onsite and offsite organizations for coping with emergencies, anc the means for notification, in the event of an emergency, of persons assigned to the emergency organizations; B.
Contacts and arrangements mace and cocumented with local, State, and Federal governmental agencies witn responsibility for coping with emergencies, including identification of the principal agencies.
The size of the EPZs for a nuclear power plant shall be determined in relation to the emergency response needs and capabilities as they are affected by such local conditions as demography, topography, land characteristics, access routes, anc local jurisdictional boundaries.
Generally, the plume exposure pathway EPZ for lignt water nuclear pcuer plants shall consist of an area about 10 miles radius anc the ingestion pathway EPZ an area about 50 miles in radius.
EPZs are ciscussed in NUREG-0396.
The size of the EPZ's for non-power reactors shall be determined on a case-by-case basis.
17b7 343 2:.
s y
[ ALTERNATIVE A C.
Protective measures to be taken in the event of an accident within the site boundary and within each EPZ to protect health and safety; corrective measures to prevent damage to onsite and offsite property; and the expected response, in the event of an emergency, of offsite agencies] OR
[ ALTERNATIVE B C.
Protective measure to be taken in the event of an accident within the site boundary and within each EPZ to protect health and safety; pro-cecures by wnich these measures are to be carried out (e.c., in the case of an evacuation, who authorizes the evacuation, how the public is to be notified and instructed, how the evacuation is to be carried out); and the expectec response, in the event of an emergency, of offsite agencies];
D.
Features of the facility to be provided for onsite emergency first aic and cecentamination, and for emergency transportation of onsite incividuals to offsite treatment facilities; E.
Provisions to be made for emergency treatment at offsite facil-ities of individuals injured as a result of licensed activities; F.
Provisions for a training program for employees of the licensee, inc!uding those uno are assigned specific authority and responsibility in the event of an emergency, and for other persons not employees of the
'cer.see whose assistance may be needed in the event of a radiolcgical e e gency; G.
Features of the facility to be provided to ensure the capability for actuating onsite crotective measures and the capacility for f acility 1787 344 24
Y reentry in order to mitigatte the consequences of an accicent or, if appro-priate, to continue operation; H.
A preliminary analysis which projects the time and means to be ecployed in the notification of State and local governments and the public in the event of an emergency.
A preliminary analysis of the time required to evacuate various sectors and distances within the plume exposure pathway E?Z for transient and permanent populations.
III. The Final Safety Analysis Report The Final Safety Analysis Report shall contain the emergency plans for cc:ing with emergencies.
The plans shall be an expression of the everail concept of operation, which describe the essential elements of acvance planning that have been considered and the provisions that have been made to cope with emergency situations.
The plans shall incorporate information about the emergency response roles of supporting organi:ations and offsite agencies.
That information shall be sufficient to provice assurance of coordination among the supporting grouts and between them anc :ne licensee.
[ ALTERNATIVE A The plans submitted must include a description of the elements set cut in Section IV to an extent sufficient to demonstrate that the plans
- rovice reasonatie assurance that appropriate measures can and will be taker. in the event of an emergency to protect public health and safety anc,ini.-ize camage to property within the Emergency Planning Zones (EPIs). ] OR 25 1787 345
Lewww weg
[ ALTERNATIVE B The plans submitted must incluce a description of the elements set out in Section IV to an extent sufficient to demonstrate that the plans provide reasonable assurance that appropriate measures can and will be taken in the event of an emergency to protect public health and safety within the Emergency Planning Zones (EPZs).2]
IV.
Content of Emergency Plans The applicant's emergency plans shall contain, but not necessarily be limited to, the following elements:
organization for coping with radiation emergencies, assessment action, activation of emergency organiza-tion, notification procedures, emergency facilities and equipment, training, maintaining emergency preparedness, and recovery.
The applicant shall also provide an analysis of the time required to evacuate various sectors and distances within the plume exposure pathway EPZ for transient anc permanent populations.
A.
ORGANIZATION The organization for coping with raciological emergencies shall te described including definitions of authorities, responsibilities and cuties of individuals assigned to licensee's emergency organization, and the means of notification of such individuals in the event of an emergency.
Specifically, tne following shall be includec:
1.
A descriction of the normal plant operating organization.
2.
A description of the onsite emergency resconse organization with a cetailed discussion of-a.
Authorities, responsibilities and cuties of the,incivicual(s e
who will take enarge curing an emergency; 1787 346-25
E b.
Plant staff emergency assignments; Authorities, responsibilities, and duties of an onsite c.
emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.
3.
A description of the licensee headquarters personnel that will be sent to the plant site to provide augmentation of the onsi e emergency organization.
4.
Identification, by position, of persons within the licensee organization who will be responsible for making offsite dose projections and a description of how these projections will be mace and the results transmitted to State ard local authorities, NRC, FEMA and other appropriate governmental entitics.
5.
Identification, by position anc function, of other employees of the licensee with special qualifications for coping with emergency conditions which may arise.
Other persons with special qualifications, such as consultants, who are not employees of the licensee and who may be called upon for assistance for short-or long-term emergencies shall also be identified.
The special qualifications of these persons shall be described.
6.
A description of the local offsite services to be provided in support of the licensee emergency organization.
7.
Identification of anc expected assistance from appropriate State, local, and Federal agencies with rescensibilities for coping with emergencies.
1787 347 27
u.,., w v.;
8.
Identification of the State and/or local officials responsible for planning for, ordering, r.otification of, and controlling appropriate protective actions, including evacuations when necessary.
B.
ASSESSMENT ACTIONS The means to be provided for determining the magnitude and continued assessment of the release of radioactive materials shall be described including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies and the Commission and other Federal agencies, and the emergency action levels that are to be used as criteria along with appropriate meteorological information for determining when protective measures should be considerec within and outside the site boundary to protect health and safety and prevent camage to property.
The emergency action levels shall be basec on in plant conditions and instrumentation in acdition to onsite anc offsite monitoring.
These emergency action levels shall be discussed anc agreed uoon oy tne applicant and State anc local governmental autho-rities and approved by NRC.
They shall also be reviewed with the State and local governmental authorities on an annual basis.
C.
ACTIVATION OF EMERGENCY ORGANIZATION ine entire spectrum of emergency conditions which involve the alerting or activation of progressively larger segments of the total emergency crganization shall be described.
The communication steps taken to alert or activate emergency personnel under eacn class of emergency snall be cescribed..__{ge_rgency action levels (od:ed not only on onsite and offsite raciation monitoring information but also on readings from a numoer of 1787 MB 2s
[7590-01]
sensors that indicate a potential emergency such as the pressure in con-tain ent and the response of the Emergency Core Cooling System) for notifi-cation of offsite agencies shall be described.
The existence, but not the details, of a message authentication scheme shall be noted for such agencies.
D.
NOTIFICATION PROCEDURE 5 1.
Administrative and physical means for notifying, and agreements reached with, local, State, and Federal officials and agencies for the early warning of the public and for public evacuation or other protective measures, should they become necessary, shall be described.
This descrip-tien shall include identification of the principal officials, by title and acencies, for the Emergency Planning Zones 2 (EPZs).
2.
Provisions shall be cescribed for the yearly dissemination to the puclic within the plume exposure pathway EPZ of basic emergency planning information such as the possibility of nuclear accidents, the potential hu an health effects of such accidents and their causes, methods of r.otification, and the protective actions planned if an accident occurs, as well as a listing of local broadcast network that will be used for disse-ination of information during an emergency.
3.
Administratise and physical means, and the time required, shall be cescribed fnr alerting and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone.
It is tre applicant's responsibility to ensure that such means exist, regardless cf who irplements this requirement.
It is expected that the capability will be provided to essentially cceplete ale-ting of the public within the plume exposure pathway EPZ within 15 r.inutes of the notification by the licensee of local and State officials.
}]h b
29
E.
EMERGENCY FACILITIES AND EQUIPMENT Provisions shall be made ar.d descriced for emergency facilities and equipment, inclucing:
1.
Equipment at the site for personnel monitoring; 2.
Equipment for determining the magnitude of and for continuously assessing the re.1 ase of radioactive materials to the environment; 3.
Facilities and supplies at the site for decontamination of onsite incividuals; 4.
Facilities and medical supplies at the site for appropriate emergency first aid treatment; 5.
Arrangements for the services of a physician and other medical personnel qualified to handle radiation emergencies; 6.
Arrangements for transportation of injured or contaminated indi-vicuals from the site to treatment facilities outside the site boundary; 7.
Arrangements for treatment of individuals injured in support cf licensed activities on the site at treatment facilities outsice the site councary; 8.
One onsite tecnnical support center and one near-site emergency operation center from which effective cirection can be given and effective control can be exercised during an emergency; 9.
At least one onsite and one offsite communicatiens system, inclecing reduncant power sources.
This will include the communication arrangements for emergencies, including titles and alternates for tnose in cnarge at both ends of the cor.munication linkc anc the primary anc
- acxup means of ccmmunication.
Where consistent with function of the ge.ernmental agency, these artangements ill incluce:
1787 350 20
..s a.
Provision for communications witn contiguous State / local govern-cents within the plume exposure pathway Emergency Planning Zone.
Such communications shall be tested monthly.
b.
Provision for communications with Federal emergency response organizations.
Such communications systers shall be tected annually.
c.
Provision for communications between the nuclear facility, State and/or local emergency operations centers, and field assessment teams.
Such communications systems shall be tested annually.
F.
TRAINING The program to provice for (1) the training of employees and exer-cising, by periodic drills, of radiation emergency plans to ensure that employees of the licensee are familiar with their specific emergency re-sponse duties, and (2) the participation in the training and drills by other persons whose assistance may be needed in the event of a radiation e.?.ergency shall be described.
This shall include a description of special-i:ed initial training and periodic retraining programs to be orovided to eacn of the following categories of emergency personnel:
a.
Directors or coordinators of the plant emergency organization.
b.
Personnel responsible for accident assessment, including control room shift personnel.
c.
Radiological monitoring teams.
d.
Fire control teams (fire brigades).
e.
Repair and damage control teams.
f.
First aid and rescue teams.
g.
Local services personnel, e.;.,
local Civil Defense, local law enforcement personnel, and local news media persons.
\\7Bil.551 31
D
- D'9~
u1d
- d a
2 6,...
w.s h.
Mecical suspcr. perscnnel, i.
Licensee's heaccuarters support personnel.
j.
Securi.y persennel.
Tne plan shall cescrice provisions for the concuct of yearly drills i
8 anc exercises te tes the acequacy of ticing anc content of implementing procecures anc me:hect, tc test emergency ecuipment and communication netwer(s, anc :: ensure that emergency organization personnel are f amiliar with neir cuties.
Such provisions shall specifically include participa-tion by offsite personnel as cescribec aoove as well as other State and local ;cve-rrer.tal agencies.
Tne plan snail also cescribe provisions for a joint exercise invel d n; the Fecerai, State, anc local response Organizations.
The sccee of suc.' an exe cise snould test as much of the emergency plans as is reasonaDly acnievacle witncu; involving full puclic participation.
Definitive ce 'creance crite 'a snail be establishec for all levels of participaticn ic ensure ar. ccjective evaluation.
This joint Feceral, State, anc 1cca eve cise snal' te:
1.
fer cresent',' ocerating plants, initially witnin one year cf the ef'ective ca:e of tnis amencment and once every [ ALTERNATIVE A inree years] or [ ALTERNATIVE S five years] thereafter.
3.
fc a plan for wnicn an coerating license is issued after the effective cate of :nis amencment, initially within one year of
- ne issuance of tne C0erating license and once eve y [ ALTERNATIVE A three yea s: cr [ ALTERNATIVE B five years] thereafte-All traini9g Orevisions snali provice for formal critiques in orcer
- evaluate tne e.ergency D'an's effect veness anc tc correct weak areas i
1787 352'
-,SL
l
[7590-01]
I througn feedback with emphasis on schedules, lesson plans, practical training, and periodic examinations.
G.
MAINTAINING EMERGENCY PREPARE 0 NESS Provisions to be emoloyed to ensure that the emergency plan, its im lementing procedures and emergency equipment and supplies are main-tained up to date shall be described.
H.
RECOVERY Criteria to be used to determine wnen to the extent possible, following an accident, reentry of the facility is appropriate or when operation shculd be continuec.
V.
Imolementing Procecures No less than 180 days prior to scheduled issuance of an cperating license, 10 cocies each of the acclicant's detailed im:lementing proce-cures for its emergency plan shall be suomitted to NRC Headquarters and to tne appropriate NRC Regional Office:
Provided that, in cases where tne ocerating license is scheculed to be issued less than 180 cays after the effective date of this rule, such implementing procedures shall be submitted as soon as practicable.
Within 60 days after the effective cate for compliance under S 50.54(v) with the revised Appendix E, licensees wnc are authorized to coerate a nuclear power facility shall submit 10 cecies each of the licensee's emergency plan implementing protecures to NRC Headquarters and to the appropriate NRC Regional Office.
As necessary te r.aintain them up to date thereafter, 10 copies eacn of any changes to tnese im:lementing procedures shall be submitted to NRC Heacnuarters and to tne same NRC Regional Office within 30 days of such enanges.
1787 353 33 Enclosure "A"
[7590-01]
(Sec. 161, Pub. L.83-703, 68 Stat. 948 (42 U.S.C. 2201); Sec. 201, as amended, Pub. L.93-438, 88 Stat. 1242, Pub. L. 94-79, 89 Stat. 413 (42 U.S.C. 5341).)
Dated at Washington, D.C. this k
day of R_t m l w 1979.
For the Nuclear Regulatory Commissien.
_,iS I
Samuel J.\\ Chilk Secretary of thb Commission 1787 354' 34
Enclosure No. 2 AGENDA FOR Ep1ERGENCY PREPAREDNESS WORKSHOPS Morning Session
-- 8:30 a.m.
Introduction
- Purpose & Scope of Meeting.
Background-Reason for proposed Rule.
- Proposed Rule provides for Federal / State / Local planning for emergencies.
- NRC Emergency Planning requirements-concurrence required.
Presentation of Proposed Rule
- Rationale for and description of proposed rule.
- Criteria to be met for concurrence.
- Who must have concurrence?
Review and concurrence procedures.
- Differences in requirements for emergency planning zones, i.e. plume exposure zone for compared to ingestion pathway zone.
Federal Emergency Management Agency (FEMA)
Role in overall emergency preparedness, training, funding, and model plan development.
Public Affairs Role of public af f airs officials in an emergency, coordination between " responders" and the media.
Questions and Comments From General Public
[787 355-i
2 Afternoon Session
-- 1 :00 p.m.
Discussion By Particicants Discussion Points:
Requirement tnat State and local emergency response plans be concurred in by the NRC as a condition of operating license issuance.
(NRC concurrence in State anc locel plans is not required at the construction permit stage.) Additionally:
a.
An operating plant may be required to shutdown if a State or local emergency plan has not received NRC concurrence within 180 days of the effective date of the final amendments, or January 1,1951, whichever is earlier.
b.
An ooersting plant may be required to shutdown if a State or local emergency plan does not warrant continued NRC concurrence and is not corrected within 4 months of notification of NRC concurrence withdrawal.
(Discussion will include consideration of alternative proposed rules for permitting continueo operation or issuance of operating licenses for an interim period where there are no concurred in plans or concurrence has been withdrawn). -
1787 356
Requirement that emergency planning be expanded to cover " Emergency Planning Zones".
- Requirement that detailed emergency planning implementing procedures be submitted to NRC for review.
- The requirement that specified " Emergency Action Levels" be used by the applicant, State and local authorities.
- Provisions for promot alerting of the public and instructions for public protection.
Requirements for having Emergency Operations Center.
Requirement for providing redundant communications systems.
- Requirement for providing specialized training to licensee and local emergency support personnel.
Requirement for maintaining up-to-date plans.
- What measures can compensate for various deficiencies.
Closir.g Session Individual statements / comments by participants and public.
- Concluding statement by NRC.
Adj:u-n
-- 5:00 p.m.
1787 357
Enclosure No. 3 SCHEDULE January 15 Roosevelt Hotel Madison & 45th Street New York, New York 10017 212-661-9600 January 17 Bellevue Hotel Geary at Taylor Street San Francisco, California 94102 415-392-7752 January 22 Ramada O' Hare Inn 6600 N. Mannheim Road Des Plaines (at O' Hare Airport) 312-827-5131 January 24 Downtown Holiday Inn 175 Piedmont, NE Atlanta, Georgia 30303 404-659-2727 1787 358
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~ {
,o, UNITED STATES
( ^2 NUCLEAR REGULATORY COMMISSION
~
f i
WASHING TON, D. C. 20555 g,u/
.....f December 26, 1979 APPLICANTS FOR CONSTRUCTION PERMITS AND LICENSEES OF PLANTS UNDER CONSTRUCTION Gentlemen:
SUBJECT:
REQUEST FOR INFORMATION REGARDING EVACUATION TIMES This letter is being sent to all applicants for construction permits, and licensces of plants under construction. The purpose of the letter is a request for information regarding estimates for evacuation of various areas around future nuclear power plants.
The requested information is in addition to that requested by the November 21, 1979, letter to all applicants for an operating license and licensees of plants under construction from Domenic B. Vassallo, Acting Director, Division of Project Management, 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 previously specified 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 information requested in the enclosure should be submitted no later than March 31,1980.
Previous correspondence 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 in the near term.
The upgraded plan development should therefore proceed on a site-specific basis.
Sincerely, I
/-)m h
x
,u s r i ~ S-L DUPLICATE DOCUMENT
Enclosure:
0 "*#
P"*
"* D
" l#*
9 Request for Evacuation Time entered into system under:
Et h
b ANO cc w/cnclosure:
~
Service Lists No. of pages:
f7B7 359