ML19320C707
| ML19320C707 | |
| Person / Time | |
|---|---|
| Issue date: | 07/03/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19320C708 | List: |
| References | |
| REF-10CFR9.7 SECY-80-275B, NUDOCS 8007170597 | |
| Download: ML19320C707 (60) | |
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NRC 1l UNITED STATES OF AMERICA Comm.
j 7/80 2
NUCLEAR REGULATORY COMMISSION Parker bfml 3
PUBLIC MEETING tl 4
STAFF RESPONSE TO PANEL PRESENTATIONS ON EMERGENCY e
5 PLANNING Me i
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i k7 Nuclear Regulatory Commission
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Room 1130 8
8 1717 H Street, N.W.
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Washington, D.C.
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Thursday, July 3, 1980 h
10 E
l The Commission met, pursuant to notice, at 2:03 p.m.
G 11 BEFORE:
d 12 l JOHN AHEAid.E, Chairman of the Commission 13 !
5 i
JOSEPH HENDRIE, Commissioner E
14 NRC STAFF PRESENT:
2 15 l K. GOLLER J
16 f G
j M. JAMGOCHIAN j
17 ;
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B. GRIMES 5
18 5
M. MALSCH I
19 !
A W.
DIRrKS 20 !
I R. MINOGUE 21l l
SAMUEL CHILK, Secretary 22 l LEONARD BICKWIT, General Counsel i
23 '
l ALSO PRESENT:
I 24 l THIS DOCUMC!T CONTAINS POOR QUAUTY PAGES JOHN MC CONNELL, EPA g
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ALD RSON REPORTING COMPANY, INC.
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_P _R O _C _E _E _D _I _N _G _S.
2 CHAIRMAN AHEARNE:
Last week, we had a meeting in which 3
we heard from three groups representing a spectrum of opinions 4
regarding our proposed emergency planning rule.
Following that, 0
5l I asked the staff to prepare a response to the principal points 0
j 6l made by'each of the panels in that meeting and suggested it R
7 would be useful for the Commission to be briefed on those n-l 8'
responses today.
Oy 9
I assume that is the purpose of today's meeting.
Karl?
i zo 10 MR. GOLLER:
Yes, it certainly is.
We would like to 3
11 discuss those comments, which the Commission heard at that
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12 meeting.
We would like to discuss not only the staff's response "5
5 13.
to these, but also wher.e appropriate, some changes that the l
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I4 staff would like to suggest to the Commission that might be 5
15 made in response to these comments.
j 16 These comments that were made by these three panels e
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- 37l, can be generally divided into five principal issues which are
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18 listed on this slide.
May I have the next slide, please?
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(Slide.)
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20 We will discuss the major specific comments under 21 l each of these principal issues.
Firstly, I would like to note 22 that SECT-80-275B, another addition to the basic sucmission to i
23 '
the Commission, dated July 2, 1980, has been submitted to the 24 Commission which suggests a. number of wording changes to clarify 1
the requirements of the rule.
25 i
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Most of these are in response to the comments that bfm3 2
were made by the panels, either during the meeting with-the 3
Commission or in their written statements, which;some of them 4
submitted.
This staff paper to the Commission also proposes to 5
g incorporate all of the changes recommended by the General n
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6l Counsel in his memo of June 24 to the Commission, relative to R
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These provisions would add considerable more flexi-d q
9 bility to the rule, especially on the Commission's prerogatives zo g
10 when all of the requirements of the rule are not me' in a parti-z=
1 11 cular case.
The Commission paper 275B also proposes to make 3,
N 12 f certain changes requested by NMSS, which would clarify the fuel 5
j 13 l cycle facilities are not subject to some of the requirements in
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14 the rule, particularly the standards or design objectives as 5j 15 they were previously called, and are called in NUREG-0654; and
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y 16 the requirements for periodic exercise of the plants.
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CHAIRMAN AHEARNE:
What is -- why are NMSS scaff Eu 3
18 making that recommendation?
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MR. GOLLER:
I would like to note again that it is 9
I 20 l simply a clarification of what was the original intent.
The 21
. reason is that a separate rulemaking process for these types of 22 facilities is ongoing.
The more appropriate emergency planning 23 requirements for those kinds of facilities will be included in 24 j. this.
i These are fuel cycle. facilities other than power l
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I reactors of which there are relatively few in number and on 2
which we expect to be back before the Commission in the near 3
future with a special tailored rule for those facilities.
4 The major difference being the type of accident e
5 scenarios that are appropriate for consideration.
-3 6
h CHAIRMAN AHEARNE:
You mentioned NMSS.
Bill Dircks, 8
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arise.
8 8
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MR. DIRCKS:
If you recall, we did put some more d
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people into that question after the Three Mile Island accident.
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They are working on the radiological plants now.
-E 11 MR. GOLLER:
If I could have the next slide then, d
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(Slide. )
E 14 The first issue was that of implementation schedule.-
2 15 5
Several comments were made by the different panels on this y
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matter.
Some that the staff proposed the implementation p
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schedule is too short; others too long.
After careful considera-5 18 5
tion of all the factors, the staff has concluded that they wish 19,l ea i
to recommend to the Commission that the imolementation cchedule 20!
21l be postponed slightly by three months from the previous January l
l 1, 1981 until April 1, 1981.
22 f CHAIRMAN AHEARNE:
Now, the state people were here.
23 ;
They said they could not meet it.
As I recall -- at least my l
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j notes that I reviewed -- they were saying they could not meet j
25-it unless it were extended until July.
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MR. GRIMES:
It is my understanding that there is a 2
mix of ability to meet it.
For example, Illinois and Pennsylvania 3
we talked to.them separately and they thought they could meet it; 4
however, New York and California, they thought they could not.
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New York was the longest one, thinking it would take approximately 0
3 6l until July.
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There is a California law which would require implemen-3 j
8 tation by March 25, 1981 of the plan.
d 9l CHAIRMAN AHEARNE:
Implementation or --
2o 10 MR. GRIMES:
Implementation of the plans.
E II CHAIRMAN AHEARNE:
All right.
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MR. GRIMES:
If they meet their own schedule, they a
j 13 l would meet this schedule.
I would not rule out that we might i
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14 l have to have one or two exceptions, or exemptions to the rule.
15 I would also point out that the rule is not to cause shutdown of E
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a plant on April 1.
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I7 It is only when we get a finding'that there is not E
18 adequate preparedness from FEMA that we would proceed to do ch I9 l this.
Everyone would be substantially upgraded by that date, g
l 20 although all provisions would not be in.
2I Later on, or even at that date, if we get a finding 22 from FEMA that there are inadequate plans, thera is a four 2.
month period in which deficiencies could be corrected.
I think 24 there is some glexibility beyond the April 1st date.
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CHAIRMAN AHEARNE:
What led you to change from January I
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to April?
2 MR. GRIMES:
Essentially the concern of the states 3
that they could not -- they would be far beyond -- some states 4
would be far beyond the January 1 date.
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FEMA's assessment of all the dates -- everyone will E"
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6: have substantially upgraded plans by about April 1st or early e
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7 spring.
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CHAIRMAN AHEARNE:
Are you saying that FEMA has an N
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9 estimte that says the plans will be -- most everyone will have I
10 implemented their plans by --
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11 MR. GRIMES:
Not entir'e implementation, no.
I under-
<3 12 stand they believe most plants will be upgraded substantially 4
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15 MR. GOLLER:
Mr. Chairman, it is important to realize E
i 16 i you have a four month period.
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No, I know that.
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Which runs -- okay.
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19 MR. GRIMES:
Also, one consideration in not planning xn i
20 l too far is we are very concerned, we get as soon as possible 21 substantial improvements around these plants.
We are reluctant 22 to dilute that effort that is now ongoing and full-force, and i
23 has been going most places with the aim of getting things ready I.
24 l by January 1.
s 25 MR. GOLLER:
The implementation date for the notifica-1 J
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tion capabilities is still the same as SECY-275A document, July 2
1, which is a six month extension beyond what was originally 3
proposed.
Here again, there is a four month -- there would be 4
a four' month period beyond that before the rule would provide for s
5 some definite action to be taken.
6 (Commissioner Bradford enters the room at 2:13 p.m.)
R 7
MR. GOLLER:
The proposed change, I might mention, is sj 8
item 6 in the SECY-275B document, and the associated replacement d
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9 pages that would provide that change if the Commission decided 2o 10 to do that.
_E IIl CHAIRMAN AHEARNE:
Go ahead.
3 12,
MR. GOLLER:
The next specific comment under this 5
l 13 I general area of inplementation schedule indicated on the slide l
14 was that some utilities -- licensees indicated it would be two
$j 15 years to complete implementation.
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g 17 i this long a period actually applied primarily to major structures, 5
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construction of new structures such as a technical support cs 19 e
center or emergency operating -- operations facility, and that a
20 interim accommodations could be provided which would be -- which 21f would fully be satisfactory and satisfy the requirements of the 22 rule.
23 While that kind of construction was completed, again 24 l it is our opinion that by far and away, most of the licensees il 25 h could meet this state.
There might be a few exceptiens that a-h i
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1 we would have to focus on individually.
2 However, we think it would be wise to e.ttain these 3
dates and thereby encourage early implementation.
4 COMMISSIONER HENDRIE:
I think it is not unreasonable.
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On the one hand you do not want to put in place a rule which 8
6 people who have to implement it and have the state officers tell R
7 you it is flatly impossible in spite of their best efforts.
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the other hand, you do not want to relax it so that everybody d
9 goes away and promptly starts a month's summers vacation before 3
5 10 they get back to work.
$ IIl You like to put the pressure up.
It seems to me a a
p 12 reasonable middle course is being proposed here.
EaS, 13.
Relative to the " moving target" and MR. ' GOLLER:
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5 14 l increasing requirements comment, it is the staff's position that 5
15 the major requirements of the rule have not changed significantly 16 during the rulemaking process, which has been under way for J
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some time.
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3 18 These have been publicized.
The staff has been i
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encouraging the development of these plans, as most of these are n
20 well under way.
Finally --
2I CEAIRMAN AHEARNE:
I though that had very little --
l 22 l
.there was very little substance.
I agree completely with you, i
I 23 Karl.
24!
MR. GOLLER:
We are proposine to add now another three !
1 25 l months to the implementation schedule.
So, we think this is a I
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reasonable schedule that we have already been discussing.
The 2
lastbommentindicatedontheslide, the fact that -- the 3
contention that the rule does not address the federal role.
It 4
is the staff's position that it would be inappropriate for an g
5 NRC regulation to do so: to essentially promulgate regulations a
6l on itself or other federal agencies.
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Furthermore, the national contingency plan, which will n
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set forth the federal role, is well under way in preparation.
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FEMA is coordinating this effort.
It is scheduled to be comple-
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10 ted this September.
That would include the NRC agency's plan, z=
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11 which is par t of this national contingency plan.
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12 Lastly, the point is that licensees' state and local
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NRC has indi-a mg 14 cated'all along that its -- and other federal agency activities j
15 will be strictly advisory.
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16 COMMISSIONER BRADFORD:
The national contingency plan M
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17 is nuclear power plant accidents only, or all sorts of centin-w Ew 18 gencies?
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MR. GOLLER:
Initially, the focus will be nuclear n
20 power-plants.
My understanding is that it is FEMA's intention 21 to eventually extend this to include other matters.
Perhaps 22 there is a representative from FEMA that could expound on that.
23 '
MR. MC CONNELL:
Yes, Mr. Commissioner, that is 24 l essentially true.
We are making certain that we have all the 25 :
aspects of the commercial power plant, federal support plans I
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included in this plan initially.
We also plan to include other 2
reactors of DOD and DOE eventually, and fuel cycle facilities, 3
perhaps waste disposal areas and transportation accidents per-4 taining to radiological releases.
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It is a contingency plan for n
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MR.
Mr.' CONNELL:
Yes, nuclear only.
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If there are no other questions on this d"
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principal issue, I would like to move on to the next one.
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12 This is the technical bases for specific requirements
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There were specific questions and comments about I
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the bases for the ten mile plume exposure, EPZ distance, emer-k 9
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gency planning zone distance.
Expert opinions as to what this 16 3
distance or emergency planning should be do range over some I
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distance; approximatelt from five to up to 12 miles.
Ew 18 Ten miles is a conservative judgment value.
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CHAIRMAN AHEARNE:
If you are going to talk about the a
20 l range of opinion or, at least I'm not sure how you would qualify 21 i expert.
There are ranges talked about much further than 12 22 l miles.
23 MR. GRIMES:
Perhaps that should be qualified to 24 government bodies, technical experts.
I think the 12 miles j
23j corresponds to a~20 kilometer distance picked by some nations, l
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including Canada.
There certainly is -- are other opinions which 2
would.take this distance much much further.
3 For example, in the case of thyroid blocking, there 4
have been recommendations to go to 100 or 200 miles with 5
j potassium iodide pills.
I think we heard a number during the n
6l public comment session on 47 miles by the American Physical R
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So, I think we would have to qualify that as govern-Mj 8;
ment expert opinion, rather than the total body of opinion.
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CHAIRMAN AHEARNE:
Are vou discounting the APS?
Are z
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you clarifying the 47 miles?
What is your position on that?
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I think you would have to look at what a
f I2 those people would suggest be done over that distance, the ten
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mile distance specified in the rule is primarily one for a a
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h I7 l unlikely event that it should become necessary to extend beyond 5
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ad hoc basis.
The provisions that would have been made for the 20 l ten mile distance would easily enable that kind of extension 21 beyond the ten mile distance.
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All of the planning that is done does not involve any i
23 l' sharp cut-off of that distance, which is not -- could not be 24l applied beyond.
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Also, in the other direction, the recuirement is for l
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2 MR. GRIMES:
We should also mention that it is not 3
strictly a ten mile requirement.
Ten miles applies to immediate 4
protective actions for the public.
There is also a 50 mile y
5 dist&nce wittin which food pathway considerations are primary.
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Preplanned actions to be able to intercept are taken into con-R 7
sideration.
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required for further distances.
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10 MR. GOLLER:
On the other side, there were come ques-3l 11 tions raised about whether the distance should not be less than 3
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This is a requirement for notification capability and
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2 15 notification and implementation in an actual case was possible, E
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16 perhaps even probable.
Some rewording in the rule and the A
d 17 i supplemental information that accompanies it now makes that E
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That is the state and local government's prerogative..
P 19 l If the -- if they deem it appropriate under a particular 5
20 l accident that a graded notification and implementation would be 21 quite appropriate.
22 CHAIRMAN AHEARNE:
Could you point out to me where I 23 would find that point that a graded notification system would be i
24 l acceptable, or appropriate?
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MR. GRIMES:
In the supplemental information in the i
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earlier package.
Not in 275B.
2 MR. GOLLER:
275A.
3 MR. JAMGOCHIAN:
Excuse me, it is on page 26 of the 4
original package that was sent up to you.
If you would like, I g
5i would read it.
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6 CHAIRMAN AHEARNE:
It is not 275A, either.
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7 MR. JAMGOCHIAN:
No, no.
It is 275A.
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8 CHAIRMAN AHEARNE:
275.
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9 MR. JAMGOCHIAN:
Page 26.
It says, "Some comments rog 10 received on the proposed rule advocated the use of a staged 3
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13 "The condition believes that the condition for quick
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16 the option of selectively actuating part of the system during an s
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actual response.
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" Planners should carefully consider the impact of the P
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added decision that off site authorities would need to make, M
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21 links to all residents inthe plume exposure pathway emergency 22 planning zone when determining whether to plan for a staged i
1 23 l notification capability."
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MR. GOLLER:
A closely related comment for questions 25 -
on.the 15 minute notification capability, and again the basis 1
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therefore.
The Commission is, of course, aware that there are 2
actually two 15 minute periods in series.
More correctly, a 3
30 minute period, as indicated -- as indicated in NUREG-0396.
4, An analysis of some accidents, including some class 9 5
accidents show that releases can occur.
That is, in as short n
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a period of time as 30 minutes.
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that, there would ve additional time involved in actually taking cF 10 g
some kind of action, wahtever that might be.
Even sheltering 5
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what to do on the radio after they have been told by the initial I
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If that should be evacuation, it could take a consider-
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able period of time before it was actually consummated.
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therefore, is the basis for the staff's belief that the 15 minute cw 18 I capability is an appropriate rule.
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It is, again, to some extent a matter of judgment.
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or 20 minutes cannot be parsed that fine.
The 15 minute period 22 '
has been identified and is a consensus judgment.
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CHAIRMAN AHEARNE:
I noticed that radios seem to have 2<4 i t
i come in and our of the rules.
Is there some changing thought 25 on that?
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MR. GOLLER:
Was the word " radio" specifically men-2 tioned in the rule at one point?
3 CHAIRMAN AHEARNE:
In 275, it was not.
In 275A it is 4
the use of this notification, the capability will range from g
5 immediate notification to the public within 15 minutes to listen E
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7 Then, in 275B, it is no longer that.
I was just 5
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curious as to.the floating --
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9 MR. JANGOCHAIN:
There was no special reason for z,
oy 10 leaving it in or taking it out.
E ll MR. GRIMES:
In general, however, it is our intent that j
3 jf I2 there owuld be a message on the air at the time that people are
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I think t' ; fact that it got in later is
$j 15 simply an indication of how the thinking and the greatest
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BUt it came out in the following a
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It wasn't in in 275.
It was in 275A.
It is out in P
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275B.
I was just curious.
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20l MR. GOLLER:
That I cannot explain.
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2I MR. GRIMES:
I think we tried a slightly different 22 l approach to the 15 minute warning.
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23 CEAIRMAN AHEARNE:
All right.
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COMMISS'IONER BRADFORD:
What is the relationship l
25j between the wind soeed and the smeed that the plume travels at?
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MR. GRIMES:
DIrectly the same.
If the wind is blowing 2
at 20 miles per hour, it covers tem miles in 1/2 hour.
At ten 3
miles an hour, it takes another -- that is, the possible delay 4
time between the delivery c_' activity to the of fsite public --
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there is also a delay time in taking action, if the action is n
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7 CHAIRMAN AHEARNE:
The potential delay time between s
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initial release and initial notification.
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MR. GRIMES:
Or there may be a precautionary notice O
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This may come before 3
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I2 COMMISSIONER BRADFORD:
I mean, certainly for most
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15 then ten miles is suddenly not very great.
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Well, the time to take action then, if A
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the release is very high, would force you to take shelter rather
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18 than to evacuate as an immediate action, perhaps until the wind C"
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changed.
n 20 If it was a matter to low release, one could evacuate 2I ;
even under those conditions.
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COMMISSIONER BRADFORD:
I guess I had not realized that,l 23 '
that if in the event you were looking at a really major release, 24ld i
and you were getting the notification process simultaneously with 4
25 the release, the best advice would be to stay indoors.
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MR. GRIMES:
Yes.
Pa ticularly for a puff release, 2i which might pass over over a period of time.
3 MR. GOLLER:
Okay.
There were comments expressing con-4 cern about the specificity with which the distance of the 5
j emergency operations facility location from the site is -- is 9
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indicated, even moreso about the way that this might be applied R
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in the regulatory process.
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The rule says only that the emergency operations d"
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facility is to be located near the site.
It is not more zo" 10 y
specific than that.
It is true that the NUREG guidance document
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CHAIRMAN AHEARNE:
That would at least lead someone I
to believe that --
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'4 MR. GOLLER:
Certainly, this is not a requirement.
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we all know, this is a gnidance document.
It is already being
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A 17 Furthermore, we will reconsider'even this indication 5
18 as part of the review and refinement of this NUREG document 9"
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8 20l' MR. GRIMES:
There is also --
21l CHAIRMAN AHEARNE:
Bob, do you want to say something?
22 l
MR. MINOGUE:
I think it is important to realize that t
23 i
the rule speaks to a licensee facility, and the situation where I
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there was some desire to combine some state or local. response l
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capability with that facilitv.
That is a new ractor that would il ALDERSON REPORTING COMPANY, INC.
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lead to some flexibility in consideration of where it would be.
2 I think what Karl is suggesting, all of this is 3
evciving.
That kind of new thinking will get folded in.
The 4
regulation speaks only to the licensee facility.
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CHAIRMAN AHEARNE:
I thought in a number of places, N
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That was the initial intent of NUREG-0654.
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Separately because they wanted to x
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No, mainly becuase they have operations M
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CHAIRMAN AHEARNE:
What is the strong argument for 2
having plant facility located approximately one mile --
3 MR. GRIMES:
The argument is to facilitate management --
4 overall management of the event in a longer term situation.
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CHAIRMAN AHEARNE:
What kind of management would you 3nd.6 see going on from that facility?
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That sounds like a description of
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It doesn not necessarily 3
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The reason it is desirable to have the 5
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However, there is better -- on the other hand, there 2
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from the plant to these facilities.
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way.
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The rule could, but the description 21
-- the guidance makes it very --
22 ;
MR. GRIMES:
Right.
The guidance over the next couple I
23 of months will be revised.
24 CHAIRMAN AHEARNE:
Does FEMA have any position on where 25 that ought to be and whether there ought to be any co-locations i.
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between the -state and local people and the plant management?
2 MF.. GRIMES :
I would have to ask John McConnell if he 3
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MR MC CONNELL:
Yes, sir, Mr. Chairman.
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decisionmaking is made, and where their public information 2
pronouncements are made.
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local people; perhaps another location.
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CHAIRMAN AHEARNE:
Where would you envision the FEMA dd 9
people being?
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They will be at the place where the l
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-- in the local area of the facility.
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and pronouncements to the public are made.
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24 l CHAIMRAN AHEARNE:
Thank you", John.
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There was a comment, I believe it was from '
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the special interest group panel which maintained that the 2
3 COMMISSIONER BRADFORD:
What panel was that?
4 MR. GOLLER:
The special interest group panel.
5 COMMISSIONER BRADFORD:
The industry people?
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6l MR. GOLLER:
It could be interpreted that way.
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agenda that was out last week, this was the --
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The third one.
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The third panel which represented the z
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11 COMMISSIONER HENDRIE:
Tit.t.
On the contrary, it 3
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represented a limited number of special interest, just as the
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In any event, members of the third
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17 I (Laughter.)
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I would contend all three 26 19,
panelt had special interest.
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I picked up the terminology the Commission 21 used in advertising its schedule last week.
One of the panels 22 -
indicated that emergency planning was not a requirement for 23 either a limited work authorization or a structured permit.
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24 l would -like to point out that it is to the extent that the staff 25 considers appropriate.
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There are specific information requirements on 2
emergency planning indicatec in the proposed rule for the 3
preliminary safety analysis report.
These are intended to 4
establish feasibility, special problems that might exist at the 5
g proposed site, and to establish early on coordiantion and 9
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cooperation with the state and local governments that will have R
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to be involved in the detailed emergency plan that will also j
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MR. MALSCH:
Would this be cart of the LWA review or 2
2 10 the CP review?
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It is part of the construction permit
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It would certainly be
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considerations?
That comes under the last bullet on the C
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slide, the interaction of all of these things.
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Maybe Karl can --
2I CHAIRMAN AHEARNE:
Before you slip to the last part, 22 i
I still am interested in a response to Marty's point, because j
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be used.
2 MR. MALSCH:
Not as part of the LWA.
It might be used 3
as part_of the CP.
I am sure it would be used as part of the CP 4
review, I am just not sure what th'y intended.
That is all.
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The information will be available as part 9
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Except if you are putting infor-
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MR. DIRCKS:
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MR. MINOGUE:
Mr. Chairman, if I may interrupt here, n
20 this is addressed in the last bullet.
The CP review is straight-21 forward.
The LWA you were referring to, some of the basic 22 issues are cited:
acceptability and proper demongraphic factors 23 '
for sites, which will have to consider many of these issues for 24 i 1
emergency planning and whether emergency plans can or cannet be 25 h developed for certain population characteristics, et cetera, i
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et cetera.
That rulemaking will come to grips probably with 2
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This rulemaking simply requires that the prelimi-3
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this issue.
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The impression I come away from N
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This rule alone does not make a set.
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COMMISSIONER HENDRIE:
It certainly will not prevent
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It will not be the function of this rule 3
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meeting.
The main thrust of the commenter's point was that Ew 18 he rattled off a long list of points which he thought needed to 5j be addressed much earlier than the operating license stage.
20 In consideration of things like cps and LWAs, he 21 l~
spoke to the basic feasibility of developing plans for a site.
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i' 25 Il' This is part of a much broader body of rulemaking, l
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2 MR. GOLLER:
I think we have gotten over to the'last 3
bullet.
I am not sure I can add much more to our response of 4
that comment than to assure the Commission that as part of these 4
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three ongoing rulemaking activities, the one on emergency 3
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Mr. Chairman, if I may, I would like to 22 add to that.
Both from the industry panel and the special 23 interest panel, there wqre a number of comments that fundemen-1 l
24l tally said that certain parameters --
l 25 CEAIRMAN AHEARNE:
THe first panel and the third 4
ALDERSON REPORTING COMPANY. INC.
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panel.
2 MR. MINOGUE:
That said that certain parameters had 3
to be quantified before you could really say that you had your 4
hands on this problem.'
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something I would agree with.
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risk reduction potential compared to some of the things you 2
might do in terms of variousi engineered safety features.
3 So, really we are looking at one end of a spectrum here.
4 I think the greater risk parameters have been adequately 5
quantified to define requirements for an emergency plan rule, 6!
but they have not been adequately quantified yet to come out R
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has approved for public -- publication and advanced notice of
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E II Thank you, t
N I2 MR. GOLLER:
If we could go on then to the next 5
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I4 (Slide.)
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22 This is still going on as witnessed by the attendance 23 '
of a representative of FEMA today, and as evidenced by the 24 l meetingsthathavetakenplacebetweentherepresentativesofthe!
25 i two organizations.
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The joint preparation of the NUREG-0654 document i
2 which was published as a joint document and also as a FEMA number 3
of REP-1; several memoranda of understandings that have bee 1 4
developed between the organizations.
5 CHAIRMAN AHEARNE:
How is the emergency response memo 4
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coming?
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I believe FEMA was somewhat delayed s
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It had some key manpower diverted.
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3 14 responsibilities are not spelled out.
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Therefore, the availability of these federal plans 23 '
should not have been a problem to these organizatidns.
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1 25 t CHAIRMAN AHEARNE:
As I detected, I thought from some
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of the stat.a people what they were pointing out was that the 2l federal government was pushing them very hard to get their plans 3
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slower.
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MR. GOLLER:
On that, as I pointed out earlier, we are 4n 6
proceeding in parallel.
The federal plans will be completed in i
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Is there any kind of a group of
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tl y bgn 2 15 MR. GRIMES:
The NRC in the past has not had such --
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Perhaps Mr. McConnel from FEMA could add 20 21l to that?
CHAIRMAN AHEARNE:
John, we should put a microphone 22 f
23 '
next to you.
24$
MR. MC CONNEL:
I think I can speak loudly enough, 4
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Mr. Chairman.
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I think the interorganizational advisory group that 2
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a good representative group; they represent the two main 4
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the National Emergency Management Association, who 5
3 6
are the state emergency management directors, and the local
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Good.
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I think the National Conference of t
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Thank you.
21 ;
MR. JAMGOCHIAN:
This point was also addressed in the 22 l letters, and it is sort of understandable in that
! public comment 23 you get a lot of complaints from the local CD people that really 24l do not know what is going on at the federal level and have no 4
25j way of knowing from these meetings that John is mentioning.
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They are usually at the state level saying, "There is 2
a lot of pressure down here; what are you people up there 3
doing?"
4 It is sort of understandable.
But the public comments 5
also voiced this concern.
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There was also a comment -- perhaps more R
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authority and change the requirements and thereby necessitate a dd 9
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14 (Commissioner Hendrie lef t the conference room at b
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16 NRC would, in any case, have the final role of defining
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would be any basis for not promulgating this rule at this time.
5 20 CHAIRMAN AHEARNE:
We have been trying to work very 21 closely with them.
22 l MR. GOLLER:
If there are no other questions on this I
23l' principal issue, I would like to move on to the next one with i'
24 h the next slido.
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- 25 l (Slide) l 1
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On the recognition of state and local government 2
expertise and authority, there were several comments that there 3
was not adequate federal recognicion of these factors either 4
in general or particularly in the rule.
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(Commissioner Hendrie returned to the conference Mn 8
6 room at 3:00 p.m.)
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5 18 It is true that at this time nuclear plans seem to be
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19 leading or driving the emergency planning efforts in this 5
20 country in general, but we belive that in time they will become 21 '
part of the' general emergency planning effort for a variety of 22 hazards that exist to the public.
l 23l There was a comment that the exercise feedback 1
24 i requirements in the rule are too specific in detail.
In response !
1 25 !j to that comment, the staff is proposing to the Commission as item '
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2 of the recently submitted SECY document, 2758, some wording 2
changes which would relieve that specificity and clarify those 3
requirements.
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6, questions of cost without providing increased benefits.
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Furthermore, the staff will reconsider this point as i
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5 11 whether there might not be some change appropriate in this.
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14 COMMISSIONER HENDRIE:
Karl, I certainly agree with that.
E 15 I was going to ask:
is there any indication in the proposed i
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5 18 in the statement of considerations and supplementary information 5
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19 that 0654 as it stands right at the moment is not necessarily M
l 20 l engraven upon immutable tablets of granite and that in fact it i
21 is a guidance document?
d 22 l That is one point.
It is not a requirement.
23 !
And, secondly, there is further development of the 24) thinking and there will probably be revisions to 0654 down the i
25 line.
)
i 3
ALDERSON REPORTING COMPANY, INC.
l
8 36 dcp5 1l MR. JAMGOCHIAN:
The points you just stated are stated l
2 in,the statement of considerations and supplemental information.
3 Also in the regulation it does make sure that we are not 4
requiring 0654 by reference, that sort of thing.
We do say that
=
5 sending them back to 0654, that acceptance criteria for the 2n
,8 6
objectives listed in the regulation, could be observed or are 7l l
R R
outlined in NUREG-0654.
A j
8.
But we are very cautious in wording the footnote in d
=
9 using 0654 throughout the regulations.
Y 10 CHAIRMAN AHEARNE:
We say that 0654 has specific 3
5 11 criteria fo r the standards that must be met.
2-i d
12 l MR. GOLLER:
But, as always, this is a guidance E=
13 document.
It is well understocd in the regulatory -- the E
14 nuclear regulatory process that NUREG dccuments are even one H
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15 step further removed from being requirements that even reg guides
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'j. 16 are.
M i
17 !
And each of these, as published, has a preamble that
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E 18 states very clearly that these are a way of satisfying a rule E-
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19 ;
which the Commission has determined would be acceptable.
They n
20,
are not requirements.
i 21l MR. GRIMES:
If.cc found a place in the supplemental 22 I information that soeaks to uocoming revisions or NUREG-0654 --
i 23 '
COMMISSIONER HENDRIE:
I thought I had it and I lost I
24 +
it.
That is the reason I asked.
Whereabouts is it?
i i
25 ;j MR. GRIMES:
It is in the basic document.
i a
d ll ALDERSON REPORTINGCOMPANY,INC.
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MR. GOLLER:
As far as this particular specific issue 2
is concerned, the off-hour drill requirements, T. would also 3-just like to note that it is by no means clear that it either is 4
a good thing or a bad thing.
It is controversial and arguments e
5 can be made both ways, and exactly where we will come out as An 6l being the most optimum situation is not that clear at this time.
7 l-E It is also true that the drill -- these kinds of drills are 2
3 j
8 sometime in the future, and there is some time that will -- that dd 9
is allowed to try to come to the best conclusion on this which z
h 10 will come about as a result of the ongoing review of that NUREG 2
l 11 document, which we intend to update to a reg guide in the near 3
4 12 future.
z Ej 13,
COMMISSIONER HENDRIE:
Well, I certainly -- we certainly
=
l 14 ought not to have anything in the rule that says we are not going E
i 2
15 to do off-hour drills because while you start off during your 5
j 16 first drills -- they are best done during business hours so that w
I g
17 most people are around.
5 5
18 I do think it is quite possible that down the line we E
h 19 i will think it is useful to exercise these communication links.
M 20 ;
MR. GOLLER:
Yes, perhaps some kind of modified drill, 21 not a fullblown drill, but one that would establish availability 22 ;
of personnel and capability of communications links.
I 23 '
COMMISSIONER HENDRIE:
I live in sort of a low grade 24j of unpleasant anticipation of Stello running an NRC response I
l
. 25 center drill at 3:00 a.m. in the morning.
But I suspect we would' j
k 3
ALDERSON REPORTING COMPANY. INC l
38 dcp77 1
learn some things from that and that they would be useful.
2 MR. GOLLER:
Since tne primary focus of this meeting 3
today is to try to address the comments received by the different 4
panels, this was another one of that type of comment where there e
5 were comments in both directions.
Ma j
6 There were some people that said this was excessive, R
R 7
the costs were excessive.
There were comments in the other 8
direction, that this is exactly the kind of drill you should have n
d
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9 for the reasons Commissioner Hendrie just indicated.
i Oy 10 MR. MINOGUE:
Mr. Chairman, I found the disclaimer z
=
j 11 we were all looking for; it is in the section which deals with 3
y 12,
the effective date, and it says that --
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13 CHAIRMAN AHEARNE:
Could you refer to a page?
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l 14 MR. MINOGUE:
Page 27 of enclosure B of the original 5
2 15 paper, and it says, "It is expected that clarified versions of 5
g 16 these documents based on public comments received will be l
g,17 i issued."
5 18 In other places there is wording that makes it clear it
- r; 19,
was developed before the rule and that many of these were n
l 20j incorporated.
21 COMMISSIONER HENDRIE:
I think that is adequate.
22 MR. MINOGUE:
It was presented as a an earlier i
23 '
version whose thinking has already evolved a great deal and will i i
24 {
be further clarified.
t 25 J As Mr. Goller said, I think eventually with more i
i ALDERSON REPORTING COMPANY, INC.
39 dep8 1
experience and implementation under our belts, the desirable 2
end goal is to issue the old Reg Guide 1.101 revised to implement 3
the now current thinking.
4 CHAIRMAN AREARNE:
Karl, as you did point out, I had e
5 a note that one of the panelists said that we do not have any En requirement to have the drills in bad weather, which --
81 6l k7 MR. GOLLER:
The other two comments --
8 MR. GRIMES:
Statistically, we should have a few dn 9
drills in bad weather, based on bad weather arriving at the i
h 10 wrong time.
E 5
11 COMMISSIONER HENDRIE:
That is right, but since the
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12 ' drills are for the most part communication exercises --
2 I
h 13 CHAIRMAN AHEARNE:
I was thinking of things like E
E 14 telephone lines came down, power lines being down.
a 2
15 COMMISSIONER HENDRIE:
Well --
16 l MR. GRIMES:
B There are some cases of very bad conditions d
l g
17 ; where you might scrub the drill.
a=
18 CHAIRMAN AHEARNE:
All right, go ahead.
F E
19 :
MR. GOLLER:
The next two comments are somewhat in the x
i n
1 20} same vein; the comment that emergency power requirements for 1
21 the emergency operations facility should be extended to include 22 more than just communications.
i 23 For example, the communications requirement is thought i
i i
24 i to be or primary, essential importance and thererore is included I
25
~in the rule.
The staff will consider this suggestion and
- )
d ALDERSON REPORTING COMPANY. INC.
40 dcp9 1
consider whether it should be extended to the entire emergency 2
operations facility as part of the ongoing review of the NUREG 3
document.
4 The' redundant power requirement for the entire g
5 facility could be interpreted as part of the requirement for an 9
3 6
emergency operations facility as required in the rule.
R R
7 Therefore, this extension would be permitted by the M
j 8
rule, if promulgated as proposed now.
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9 There was a comment that the NUREG document requires i
O g
10 public notification for general and site emergencies.
I dink Ej 11 the primary thrust of this comment was that it is required to 3
y 12
- notify the public cf site emergencies.
Again, similar to E
d 13 previous responses, the rule does not require this.
The present E
i l
14 !
NUREG criteria would provide for plans for such notification in 15 such events.
E 16 '
But it does not require that this be done.
And also we g
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17 will reconsider aspart of the ongoing review whether perhaps a change
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5 18 in wording here would not be appropriate and on an informal 2
19 l basis it is indicated provisions relative to site emergency will
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20 probably be deleted from a revision of the NUREG or conversion to 21 a reg guide.
22 ;
CHAIRMAN AHEARNE:
When you say the " provisions," do i
23 you mean any provisions or that particular provision?
i i
24)
MR. GRIMES:
That particular provision; it appears in ;
i 25 j NUREG-0610, which is an appendix to 0654 under the column of d
- l ALDERSON REPORTING COMPANY. INC.
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state and local actions.
2 And it indicates notification -- prompt notification to 3
the public.
And I think that there are certainly_some things 4
or many things within the site emergency class that would not g
5 warrant notification.
I think you,want to notify people when E
l j
6j you want them to take some action.
R R
7!
There are some things very near -- some places very 3
j 8
near the plant for some site emergencies where that might be d
d 9
true.
We would have to qualify that properly.
io 10 CHAIRMAN AHEARNE:
The notification scheme still is to 3
5 11 notify the local authorities?
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12 MR. GRIMES:
Oh, yes, for all classes of actions.
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13 !
CEAIRMAN AHEARNE:
And it is their decision on going E
i E
14 further?
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15 l MR. GRIMES:
Yes, but we will try to make constructive I
j 16 l recommendations on when it is most appropriate.
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17 l MR. GOLLER:
If there are no further questions on S
1 18 '
this principal issue, I would like to move on to the next one in E
2 I
19 ;
the next slide.
5 20 l (Slide) i 21l There were several comments on the compatibility of h
22 '
the rule with the NRC fiscal year authorization bill and the l
l 23 '
provisions in the conference report that address that bill.
I l
1
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' 24 i believe the Office of the General Counsel will provide the I
l 25 response on those comments.
ii ALDERSON REPORTING COMPANY. INC.
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42 dCpil j,
MR. BICKWIT Yes.
That was the first time I heard that l
2 argument and after review of the legislative history associated 3
with the act, I do not find any merit in it.
The conference 4
report specifically provides that unless expressly changed by e
5 provisions in this conference agreement, the conferees intend that M
N 6
the Commission retain its existing regul,atory authority.
e 7
That.particular provision is strongly suggestive that E
8 what the conferees had in mind was to establish minimum N
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requirements for a role --
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10 CHAIRMAN AHEARNE: So we can go anywhere.
E 5
11 MR. BICKWIT:
You can go beyond it.
I might also read i
d 12 one particular floor statement from Senator Randolph, chairman E
3 13 of the Public Works Committee that produced this bill on the 5
i I
14 Senate side.
5k 2
15 He states:
" Reason itself suggescs the urgent need for 5
16,
emergency preparedness equally applies to new and existing l
- ^
p 17 l commercial nuclear power plants.
5 l
I 5
18
" Planning in both cases must proceed on the assumption E
19 i that accidents of varying degrees of severity can indeed occur.
8 20l The respective states must come to terms with this task.
21 "The Nuclear Regulatory Commission has in the past year 22,
become increasingly aware of and responsive'to the importance 23
- of emergency planning to its responsibility for public health 24l and safety.
j l-25 "The conference report is not intended to limit the l
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3 ALDERSON REPORTING COMPANY,INC.
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43 dcp12 1
Commission's existing authority to attend to this important 2
matter."
3 CHAIRMAN AHEARNE:
That clearly answers that.
So as 4
far as you are concerned, the drafts are fine.
MR. BICKWIT:
The drafts are fine.
It might be A
N 6
argued that they are not consistent with the language of the R
7 conference report, depending on what you mean by " consistent."
K 8
8 But there is no argument that they violate the language in the n
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9 conference report.
i h
10 MR. GOLLER:
Commissioner Gilinsky very recently 3
5 11 forwarded through his technical assistant, John A. Austin,
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12 forwarded some questions to' the staff in a memo dated July 1, 3
E 13 addressed.to the executive director, Mr. Dircks.
E I
E 14 In this memo, Commissioner Gilinsky asked staff about w
b 4
15 what special provisions exist in the rule --
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3.
16 CEAIRMAN AHEARNE:
Karl, I wondered if I could interrupt A
17 i you for a minute.
Commissioner Hendrie is going to have to leave
=
5 18 in a couple of minutes, and I wonder if I could ask abeyance a
=
E 19 minute to handle two affirmations, if we could have the A
20 l secretary handle those, so we could do that before the quorum 21 disappears.
i 22 I'm sorry; I did not raalize you were going to be 23 i getting to that, and I thought we would just make it.
24l (At 3:18 p.m. the Commission went into affirmation 25,
session.)
ALDERSON REPORTING COMPANY. INC.
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44 dcpl3 1
(3:20 p.m.)
2 CHAIRMAN AHEARNE:
All right, Karl.
3 MR. GOLLER:
The memo I previously identified was a i
4 question from Commissioner Gilinsky requesting an explanation of y
5 the extent to which the requirement for evacuation plans would 8
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6I require consideration of individuals having special circumstances.
R 2
7 Commissioner Gilinsky requested prompt response to s]
8 his question; we would like to take this opportunity to do that.
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I assume that -- I am not sure -- is Y
10,
John here?
j 11l E
No.
Well, I am sure we are all interested, but I would a
p 12 appreciate it if you could also get in touch with Jchn Austin.
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13 Go ahead.
E l
14 MR. GOLLER:
We will do that.
2 15 COMMISSIONER HENDRIE:
Since I am going to have to slip 5
j 16 out before you get down this track, let me ask you to give me A
6 17 i an advanced, a brief bottom line.
Is there anything in your 5
W 18 discussion which would change your recommendation that the 5
19,
Commission approvo publication of this rule as the language would a
20 stand from 275 as modified by A, as modified by B?
i 21 MR. GOLLER:
No, sir, there is not.
In another sentence 22,
cr two --
l 23 !
COMMISSIONER HENDRIE:
Please go ahead, then.
1 24 l MR. GOLLER:
The answer to the question is:
there is 25j nothing specifically in the rule that addresses this requirement i
ALDERSON REPORTING COMPANY. INC.
l
45 dcpl3 il other than the general requirement in the rule and in the 2
supporting guidance document, NUREG-0654, in particular, that 3
requires that all people in the area be provided for in the 4
eme'rgency planning -- in the state and local emergency plans.
e 5
Just how this is accomplished, Mr. Brian will provide R
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3 6i some additional details as to how this is being done.
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5 7
COMMISSIONER HENDRIE:
You mean Grimes Brian, well A
3 8,
known amergency planner?
n d
I d
9l MR. GOLLER:
Brian Grimes.
E 10 MR. GRIMES:
If I could have the next slide.
E_
5 11 (Slide)
<3 d
12 It indicates the rule has only very general provisions E
E 13 including -- and I can give you some copies up here -- very 2
l E
14 i general provisions which require protective measures to be in du y
15 place and administrative and physical needs for evacuation have I
j 16 l to be described in the plans.
i p
17 i The more specific requirements -- if I could have the 5
s 18 j next slide --
5 l
19 l (Slide) 95 20 The NUREG-0654 provisions, these are in the NUREG 21 document on the next page.
And those specifically call out means l
22 l for notifying all segments of the transient and resident popula-i 23 '
tion and means for protecting those persons whose mobility may be i
24 l impaired due to such factors as institutional confinement.
This !
i 25 4 elso includes people without transportation.
A i
3 ALDERSON REPORTING COMPANY. INC.
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46 dcp15 1
In practice, the way this is done is generally to do 2
two things:
provide a telephone number during emergencies which 3
people can call for special assistance in transportation; and 4
also the current thinking is the best way to identify these e
5 people is by either a computer listing available from the b
]
6 local handicapped agencies or have one particular one for R
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Hamilton County around the Sequoyah facility; that was surveyed K
j 8
and got good response.
Od 9
Then the local plans have a list of who needs special i
h 10 assistance during an emergency or special effort to notify.
That E
5 11 can be done through a. neighbor or sending a specific transportation
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12 vehicle asking them if they are mobile, asking them to come to 5-l 13 a school,' post office, or other location.
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l 14 l It is a standard thing given in the older plans; they 5
2 15 have provisions for this kind of thing.
5 y
16 COMMISSIONER BRADFORD:
Is it a requirement that the l
p 17 ;
plans will actually be reviewed for that?
N 5
18 MR. GRIMES:
That they have these kinds of provisions, E
$ -19 i yes.
.M 20 That completes --
l 21 l MR. GOLLER:
That completes our prepared presentation, 22 Mr. Chairman.
If the Commission has any other questions, we would 23 ;
be happy to try to answer them.
24j COMMISSIONER BRADFORD:
Can somebody just walk me i
25
.through how the-process of the FEMA finding and the NRC finding i
0l ALDERSON REPORTING COMPANY. INC.
i
47 dcpl6 1
would work in an OL case in the near future?
2 In other words, if there is a FEMA finding, is that 3
issue then contestable in an OL proceeding or does the commitment 4
to the rule here that the NRC finding would be based on the FEMA e
5 finding to foreclose contesting?
MR. BICKWIT:
No, it does not foreclose being 6l R
7 contested.
We would expect FEMA to come into the hearing and Mj 8
present its case and for the board t5 make the initial decision d
d 9
based on the various pieces of testimony it had before it.
6 10 COMMISSIONER BRADFORD:
Based on the FEMA finding E=
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11 does not mean based solely on the FEMA finding.
m g
12 MR. BICKWIT:
That is correct.
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MR. GRIMES:
The MOU provides for FEMA to provide E
l 14 I witnesses at our hearings.
E 2
15 CHAIRMAN AHEARNE:
I guess the term, " finding" -- what g
16 l l
is it that -- what is it you would expect, say, in the near y
17 l future on a contested case?
FEMA would actually come in?
N I
E 18 I MR. GRIMES:
Right now some sort of status report
{
19,
rather than a final approval under their new proposed rules 20 l l
which would draw a judgment with respect to how far the plan 21 met NUREG-0654 and would, say, address each of the plar.ning 22 l objectives.
l i
i i
23 '
They are, in fact, working on a prioriy basis on the j
I 24) near term OLs.
However, that does not mean that all problems 25 are solved there.
But they are --
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tl ALDERSON REPORTING COMPANY. INC.
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CHAIRMAN AHEARNE:
It is in the MOU to corne in and be 2
witnesses.
3 MR. GRIMES:
Yes.
4 CHAIRMAN AHEARNE:
Further questions?
=
5 COMMISSIONER BRADFORD:
I guess not.
I take it what h
3 6
would be foreclosed would be argding that the radius should be Rg 7
20 miles instead of 10.
j 8
MR. BICKWIT:
That is correct under the policy state-d d
9 ment; anything beyond what appears on the OL list would be Y
10 foreclosed before the boards.
El 11 COMMISSIONER BRADFORD:
Let's see, is it the policy
- 3 6
12 statement that is taking us there or --
z i
E j-13 MR. BICKWIT:
It is only the policy statement.
m l
14 COMMISSIONER BRADFORD:
Only the policy statement at 2
15 this point.
N y
16 CHAIRMAN AHEARNE:
If this rule were in place --
4 l
p 17 l COMMISSIONER BRADFORD:
Yes, that is what I --
i 18 MR. BICKWIT:
If the rule were in place, then it'would E
19 l he the rule that would be foreclosing a contest in either i
A 20 direction.
l 1
21 CHAIRMAN AHEARNE:
And less than --
l 22 MR. MALSCH:
The rule has lost some flexibility.
It 23 l says about 10 miles; the exact size and configuration determined 24 [ with relation to a bunch of: factors.
1 25;j If someone came in and said it should be 30 or 40 miles,!
i b
d ALDERSON REPORTING COMPANY. INC.
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49 dOpl8 1
it would be beyond the --
l 2
CHAIRMAN AHEARNE:
If someone came in and said 1.7 3
miles --
4 COMMISSIONER BRADFORD:
It would be foreclosed.
e 5
MR. MINOGUE:
Mr. Chairman, those site-specific factors h
6, that are identified are narrowed to a relatively small range, R
I 2
7 so you are not talking --
M l
8 CHAIRMAN AHEARNE:
Hitting the boundary of a major 0
0; 9
population center and not picking it up where it ought to be 2
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10 I picked up.
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11 MR, MINOGUE:
That kind of thing they would cover; I
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12 think the only place, though, you might get much beyond 10 miles I
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5 2
15l' Normally, for most sites, the kind of factors that 5
j 16 l are identified would lead to very,small plus and minuses around s
y 17 10 miles.
5 l
5 18 l MR. GOLLER:
Although that has not been documented in F
l
~~
l 19 l any of the documents that accompany this rulemaking, it was 20 certainly stated at the workshops, that it is the staff's intent 21 that the deviations come few and far between and only for 22 good cause, and then almost certainly by small amounts, small 23 '
distances on the order of a mile or less.
24 '
MR. GRIMES:
I would go a little beond that.
i 25 CHAIRMAN AHEARNE:
Mr. Brian --
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1 ALDERSON REPORTING COMPANY. INC..
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(Laughter) 2 COMMISSIONER BRADFORD:
You can get some quirks; you 3
can have a situation where the people 15 miles from a plant 4
may have to drive within one mile or five miles of the plant e
5 to actually avoid it.
En 3
6 MR. GOLLER:
That of course is why the rule was written e
R i
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the way it is, to provide for the special cases.
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8 CHAIRMAN AHEARNE:
Now, the rule has flexibility.
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guess -- do you intend a modification of 0654 to reflect that?
zo 10 MR. GRIMES:
We will use the same language as the z=
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rule.
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CHAIRMAN AHEARNE:
Any questions?
E 13 COMMISSIONER BRADFORD:
No.
5 s
14 CHAIRMAN AHEARNE:
I guess where we are is we have now du!
15 l heard this response; Commissioner Gilinsky will want to read the 5
i i
j 16 i transcript of this meeting, and we ought to try to plan in the I
17 i next couple of weeks to try and reach some conclusion on it.
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5 18 l All right.
Thank you very much.
1
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19 '
(Thereupon, at 3:30 p.m.,
the meeting in the above-n 20.
entitled matter was adjourned.)
21 22 i
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3 ALDERSON REPORTING COMPANY,INC.
I
ig' NUCLEAR REGULATORY CO'd14ISSION This is Oc certify that the attached proceedings before the sh in the matter of:
STAFF RESPONSE TO PANEL PRESENATIONS OF EMERGENCY PLANNING
' Date of ?roceeding:
Xny July 3, 1980 Docket llumber:
Place of ?roceeding:
Washington, D.
C.
were held as herein appears, and that this is the criginal transcript thereof for the file of the Cec =issio-David S.
Parker Cfficial Reporter (Typec)
N
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's.
- C( t
(-
w Official Reper:er (Signature)
.of e
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DISCLAIMER This is an unofficial transcript of a =eeting of the United States Nuclear Regulatory Co==ission held on er,.1 4 3
loon in the Coc=ission's offices at 1717 E Street, N. 7., Washington, D. C.
The =eeting was open to publa c.ttendance and observation.
- This transcript has not been reviewed, corrected, or edited, and it =ay contain inaccuracies.
The transcript is intended solely for general infor=ational purposes. As provided by 10 CFR 9.103, it is not parr of the for=al or infor=al record of decision of the =atters discussed.
Expressions of opinion in this transcript da not necessarily reflect final deter =inations or beliefs.
No pleading or other paper =ay be filed with the Co-4 ssion in any proceeding as the result of or addressed to any state =ent or argu=ent contained herein, except as the Co=sission =ay authorize.
TRANSCRIPT OF:
STAFF RESPONSE TO PANEL PRESENTATIONS ON EMERGENCY PLANNING 9
e 4
6
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s COMMISSION BRIEFING ON PRINCIPAL ISSUES RAISED BY THE INDUSTRY, STATE AND LOCAL COVERNMENT j
AND SPECIAL INTEREST GROUP PANELS JULY 3,1980 l
99
PRINCIPAL ISSUES RAISED BY THE INDUSTRY, STATE AND LOCAL GOVERNMENT AND SPECIAL INTEREST GROUP PANELS IMPLEMENTATION SCHEDULE TECHNICAL BASIS FOR SPECIFIC REQUIREMENTS COORDINATION OF Tile EMERGENCY PLANNING RULEMAKING FEDERAL RECOGNITION OF STATE AND LOCAL GOVERNMENT EXPERTISE AND AUTil0RITY COMPATABILITY OF RULE WITH NRC FY 80 AUTil. BILL a
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EMERGENCY PLANNING NOT A REQUIREMENT FOR LWA OR CP j
COORDINATION OF EMERGENCY PLANNING, SITING AND DEGRADED L
CORE COOLING RULEMAKING 1
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1 FEDERAL C0 ORDINATION OF EMERGENCY PLANNING ROLEt!AKING NRC/ FEMA COORDINATION NOT ADEQUATE FEDERAL RESPONSIBILITIES ARE NOT SPELLED OUT FEMA MAY BECOME TOTAL OFFSITE AUTHORITY AND CHANGE REQUIREMENTS t
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RECOGNITION OF STATE AND LOCAL GOVERNMENT EXPERTISE AND AUTHORITY STATE / LOCAL PREROGATIVES IN PUBLIC NOTIFICATION AND PROTECTIVE ACTIONS NOT RECOGNIZED NUCLEAR EMERGENCY PLANS Sil0VLD BE INCORPORATED IN NON-NUCLEAR EMERGENCY PLANS EXEliCISE FEEDBACK REQUIREMENTS T00 DETAILED NUREG 0654 0FF-il00R DRILL REQUIREMENT RAISES COSTS WITil00T PROVIDING INCREASED BENEFITS EMERGENCY POWER REQUIREMENTS FOR EMER OPER FAC Sil00LD BE EXTENDED TO INCLUDE MORE TilAN COMMUNICATIONS NUREG 0654 REQUIRES P' BLIC NOTIFICATION FOR GENERAL AND SITE EMERGENCIES J
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t UNITED sTATa5 NUCLEAR REGULATORY COMMISSION WASHINGTCN, D. c. 2csa5
^
ly2,1380 CONSEN" CALENDAR 1"EM 3scy_s0-275s E.
'Jr.:
The Commissioners 14:
dxecutive Director for' Operations, M NM i
rem:
Rcbert 3. Minogue, Director Office of Standards Develcpment ubiect:
MODIFICATIONS TO THE FEDERAL REGISTER NOTICE AND FINAL RULE CHANGE EMERGEhcY PREPAREDNESS SUEMITTED FOR CCMMISSION APPROVAL IN To prepose to the Ccmmission certain changes to the Subject Federal urcose:
)
Recister Notica and final rule changes.
iscussion:
SECY-80-275 centains preposed changes to 10 CFR Part 50, Secticn 50.33 Section 50.47 and Section 50.54, as well as clarification and expansic changes to 10 CFR Part 50, Appendix 2.
SECY-50-275A transmittad to th Ccmmission en June 25, 1980, centained replacement pages to SECY-80-27 with changes resulting frem the Ccamission briefing held on June 18,1
.z On June 25, 1980, the Cc= mission met with panels of representatives frem industry, sate and local governments and special interes greucs.
to discuss the proposed final rule on emergency precaredness.
These j
panels identified the fellcwing areas in the Federal Recistar Notica that needed clarificatien.
(1)
Consider allcwing Stata and lccal emergency respense plans to be referenced by the applicant /licansee rather than being submittad in the licansing precess.
i~ne staff preposes to previde this clarification by wording chang on pages 30 and 35 of the Federal Recistar Notica as sucwn en the replacement pages provided as enclosure 5-1.
(2)
Ccnsider rewording the requirement in the rule change fer conduc;
.ing a critique after each exercisa in crder to clarify :te in anc The staff prepesas to provide this clarification by changing the wording as indicatad en replacament page 51A, enciesure 3-2.
(3)
Further clarify the wording in.he Nctica relative :c the States adn local authorities using their judgement in making the cacisic to.activata the public nctificatien systam.
- entact:
l iike Jamgcenian, 50 4 3-5555
-2n, a seneculec for ciscussicn en July 3, 1980.
c., un :-
>n.
Th3 Commissioners 2
s The staff proposes to previde this clarification by changing the wording as indicated on replacement page 47 provide as enclosure B-3.
s (4)
OGC has recommended that the rule be reworded to provide greater procedural flexibility consistant with that in other NRC regula-tions.
The staff preposes to provide this flexibility by changing the wording as indicated on replacement pages 37 and 37a prcvided as enclosure 3-4.
These changes incorporate all changes recommended in the June 24, IS80 memo frem OGC to the Commission.
(5)
Clarify the applicability of requirements for research reactors.
The staff proposes to provide this clarif-: cation by changing. the wording as indicated in replacement pages 35, 35a 39, and 40 enclosure B-5.
Replacement page 36 is included in enclosure B-1.
(5)
Consider extending the implementation schedule for the rule.
After careful consideration of this matter the staff now proposes r-to extend the implementation data for the licensee, State and local governments frcm January 1,1981 to April 1,1981 along wit!
i a 3 month extention for suomittal of implementating precedures (frcm Decemoer 31, 1980 to March 1981).
This would be accomplishi by the wording changes which appear on replacement pages 37 and 52 of the rule change and replacement page 5 of the supplemental information, enclosure B-6.
Replacement page 37 is included in enclosure 3-4.
(7)
Clarify that the two petitions for rulemaking relating to the emergency planning regulation have not been denied.
This was stated in the draft Federal Racister Notice (Enclosure 3:
because the staff anticipated Commission ac 1on on the SECY 20-25:
(forwarded May 22, 1980) petition paper prior to action on the enclosed paper.
If this does not occur before or at the same time the Ccmmission authorizes publication of the Federal Recister Notica on the fina rule changes on emergency preparecness,- taen the staff precosas to change the wording as shown on Reciacement page 17 whicn is provided as enclosure B-7.
(8)
NMS5 has recommend changing the rule so that the standards (plan-ning objectives frca NUREG-0654) in 50.47(b) and the exercise requirements in Appendix E are apolicable only to nuclear cower l
l reactors - not other fuel cycle facilities or researen reactors.
l I
ha Comissioners 3
m.
The staff preposes to accomolish this by changing the wording as indicated on replacement pages 35, 35a, 40, 43, 50 and 52 which are provided as enclosure S-8.
2 Cost Estimates:
These changes do not change the cost estimatas projecrec in SECY-80-275.
'cordination:
Representatives of the Offices of NRR, IE, NMSS, and ELO participated in the preparation of the enclosed replacement pages for the Federal Recister Notice and rule change.
Time did not permit cbtaining formal concurrences frem these Offices.
Robert S. Minogue, Direc ar
~
Office of Standard Develcpment inclosure's:
Stated Replacement Pages Ccmissicners' cements er consent shculd be provided directly to the Office of the Secret by, c.o.b. Friday, Julv 18, 1980.
Ccmission Staff Office coments, if any, should be submitted t: the Ccmissioners NLT July 11, 1980, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and c: ment, the Ccmissioners and the Secretariat shculd be apprised of when coments may be excected.
This paper is tentatively scheduled for affimatien at an Open Meeting during the Week of July 21, 1980.
please refer to the appropriate Weekly Ccmission Schedule, when publishec for a specific date and time.
DISTRIBUTICN Cem1ssioners Ccmissien Staff Offices Exec Dir for Cperations ACRS Secretariat e