ML19351D919
| ML19351D919 | |
| Person / Time | |
|---|---|
| Issue date: | 12/09/1977 |
| From: | Ryan R NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML19351D918 | List: |
| References | |
| FRN-43FR37473, RULE-PR-50 SECY-78-044A, SECY-78-44A, NUDOCS 8011200388 | |
| Download: ML19351D919 (3) | |
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l IL.nMAl**.1CM FOR:
I'de rL 3. H;nogu ', IJirector Of fice of Standords Dev lop. ment FR0ii:
Robert G. Ryan, Director
,0ffice of State Programs SUDJECT:
COMMENTS CO.'!CERillflG Tile PROPOSED ISSUAllCE OF EFFECTIVE AMEllDMEllT T0 10 CFR 50 APPEllDIX E "Et1ERGENCY PLANS FOR PRODUCTION AND UTILIZATION FACILITIES" Thank you for the opportunity to review this Comission Action paper.
tie have the following~ conments:
The second sentence of the proposed rule change to 10 CFR 50 Appendix E will have to be modified if the Cotanission adopts the concept of generic l'rotective Action Zones (PAZs) being racommended by the fiRC/ EPA Task Force on 1:mergency Planning.
The Task Force has completed a draft report (fil' REG O'.195) or, this matter which has been forwarded to all major program oilic.s in llRC, and a st.aff briefing concerning this report is scheduled inr December 15, 1977.
He intend to ar.k State and local government organi/.ations to review and co.nnent on this draf t before forwarding it to the Conmission for action, probably in March 1970.
t Ue request that the forthcoming NRC/ EPA Task Force report be again highlighted for the Conmission (as it was in SECY-77-461), and that this memorandum be enclosed in the Commission Action paper.
We concur in the general concepts you have outlined and in the rule change i tself.
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ENCLOSURE 4 i
Standards Development Evaluation of SP coments S
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~.xws OFFICE OF STANDARDS DEVELOPMENT'S EVAlt% TION OF STATF PROGRAMS COMMENTS CONCERNING THE PROPOSED ISSUANCE OF EFFECTIVE AMEN 0MFL TO 10 CFR PART 50, APPENDIX E State Program's Memorandum of December 9,1977, forwarded comments on the proposed issuance of an effective amendment to 10 CFR Part 50, Appendix E.
State Programs noted that if the Commission adopts the concept of ger.eric Protective Action Zones (PAZ) beinq recommended by the EPA /NRC Task Force on Emergency Planning, the second sentence of the proposed rule change to 10 CFR 50, Appendix E will have to be modified.
SD has considered the SP comment and agrees that such changes would be necessary.
In addition, the existing regulations in Part 50 and Part 100 related to emergency plans would require modification at that time and a staff evaluation of the concept of generic PAZ would be necessary.
The proposed rule change calls for an evaluation of specific site characteristics, which is consistent with our existing regulations.
For example,10 CFR Part 100, Para.100.3 b.,
states that:
"Whether a specific number of people can, for example, be evacuated from a specific area, or instructed to take shelter, on a timely basis will depend on many factors such as location, number and size of highways, scope and extent of advance planning, and actual distribution of residents within the area."
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Likewise, in 10 CFR Part 50, Appendix E. Part II, the applicant is to "... assure the compatibility of proposed emergency plans with facility design features, site layout, and site location with respect to such considerations as access routes, surroundina population distributions, and land use."
The EPA /NRC Task Force draft report recommends that protective measures should be planned for within generic zones, which are specified by fixed radial distances from any reactor site for all LWR's.
Current NRC regulations require that the area for which emergency planning is recessary shall be datermined en the buis of sita specific and plant specific characteristics.
We agree with the SP memorandum in that the second sentence of the proposed rule change does require an analysis of site specific characteristics.
In so doing, however, the rule change is not only consistent with the recommendations of the Commission (relative to providing the basis for our evaluatior.) as giver to the staff at Policy Session 77-48 (October 25,1977) but is also consistent with the above mentioned regulations, while the EPA /NRC Task Force recommendations would be inconsistent with these regulations and practices.
Finally, the Task Force recomendation has not received staff or management review from within EPA or NRC and is therefore -subject to many changes.
Therefore, we recommend approval o'f the proposed rule change.
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.22 ENCLOSURE 5 Concurrence from Office of Nuclear Material Safety and Safeguards Y
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