ML20028C566
| ML20028C566 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/27/1977 |
| From: | Libarkin M Advisory Committee on Reactor Safeguards |
| To: | Moeller D Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20027A756 | List: |
| References | |
| FOIA-82-557 NUDOCS 8301100429 | |
| Download: ML20028C566 (3) | |
Text
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C. W. Hoeller, Chairran Siting Evaluation Sutcomittee
. APPG, BOARD VIEW OF PART 100 GUIDELINC DOSES On May 11, 1977 Rags Muller sent the Comittee a copy of a joint Geabrock-New England Power Project Appeal Board decision concluding that there is no need to formulate a plan for the possible evacuation or protection of the general public outside the estaolished LPZ in the event of an accidental release of radioactivity at a large nuclear p mer plant.
l This conclusion was based on a Board finding that, under the Comission's j
regulations in their current f orm " consideration is r.ot to be given in licensing proceedings to tne feasioility of discussing an energency plan for the protection (in the event of an accident) of persons located j
outside of the Lw Population Zor.e."
The Board also said that if the i
Staff or any other parties to the case feel that there is a radiological health and safety consideration favoring a different result (which, tne Board was at scne pains to point out, was not a matter brought before
. i them. and atout which they expressed no opinion) the proper renedy is to petition the Comission for a rulemaking proceeding.
Two concurring minority opinions were,also attached, both of which f avored certifying tnis question to the Cotrinsion on the basis that the Staff's support for consideration of evacuation of people beyond the LPZ nust have 'een tused on a conclusion that the Part 100 dose guidelines may no c
longer te considered to represent " acceptable" doses to rsbers of the general public in an c;tergency although they must have been at one tine.
- l The Comittee's letter on Seabrook is also quoted in this regard:
Be ACIG believes... that further attention needs to be given to evacuation of residents and transients in the vicinity even though they nay be outside the IEZ."
both the decision concerning the need for evacuation of people beyond the IM and the question of the interpretation of the Part 100 reference dose li:'.its have nw becone the subjects of an inquiry to the Comission freci the nouse Comittee on Interior and Insular Affairs requestirrg separate opinions f rom the ImC and f rom the NHC's regulatory staff as to the need Ior attention to people outside the LPZ and as to the nature of l.
the Part 100 guideline doses. This irguiry and a furtner excha x;e, wnicn in effect delays a reply until the Ccranission has cither itself l
amresseo the isa 2e or allowec Ge Appeal m aru's occiclon to become at 1n 1, ere attach 'd... _.. -.. -. -
8301100429 821210 File:
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~ D. W. Hooller June 27, 1977 Thus,whilenoacbionisanticipatedimmediatelyinresponsetothe "Udall Cmmittee's" request, the Conmission will probably have to make seco reply eventually. In view of the connection between these con-siderations and reactor siting and escrgency planning, you may wish to consider discussing this during a future Subcomittee r.eeting. If you would like to discuss this with the full Co:anittee, time will be set aside during the 207th Meeting.
By way of additional background, the Appeal Board noted four separate decisions on this same matter between 1971 and this hearirx3 (Point Beach, llidland, San Onofre 2 and 3, St. Lucie 2).
In each of these cases,' the Doard involved concluded that, by the terns of Part 100, only the LPZ could be required to be "evacuable." It is also noted that in the earliest of tnese cases (Point Beach) the Staff's opinion was that nothing in Part 100 required that populations outside tne LPZ be considered; in the current cases, the Staff takes the opposite view of the saac regulations.
It is not cicar what the basis was for the Staff opinion cited by the Board in the earlier cases tut a reading of TID-14644 (intended "to provide reference infornation and guidance on procedures and...-
assu::ptions whereby certain factors, pertinent to reactor citing as set forth in... (10 CPR 100) may in used to calculate distance requirencnts for reactor sites....") suggests that the reference values set forth in Part 100 were never intended to be construed as acceptable doses for the general public. It states:
"The whole body dose of 25 rem referred to in the above excerpts from 10 CFR 100 corresponds nunerically to the once in a lifetime accidental or emergency dose for radiation workers, which, according to NORP recomienda-tions, ncy be disregarded in the determination of their radiation exposure status. 11owever, neither its use in the context of this regulation nor that of a correspondingly low internal organ dose (such as, for exagle, the 300 rem to the thyroid might be mnsidered in this application) is interded to igly that these nurbers constitute acceptabic crergency doses to the l
public under accident conditions. Rather, this 25 rem value ard the 300 rem thyroid value have been set forth in these guidas as referen values which can be used in the evaluation of reactor sites for reactors that reflect througn tneir ocsign, construction ard operation an exceedingly lo.i protubility for a major accident, and through locatica ard otner categuards against the hazardous consequences of an accident, snould one occur, a low prob-
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values cannot be considered as being independent from the likelihood of serious accidents not from considerations of the total nts:ber of persons that might be exposed."
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In addition, the AE0 Regulatory Staff did not initially interpret these dosec as " acceptable" since there was a period when the Staff would not have considered a plant design acceptable if the Design Basis Ac-cident Calculations actually approached the reference dose values of Part 100. In fact, a 1ctte'r dated April 3,1969 froa Edwin A. Wiggin,
~ Secretary to the Reactor Safety Steering Ccanit. tee of the Atcnic Industrial Forum to Dr. Peter Morris, tnerr-Director of the AEC's Division of heactor Licensini gives the following as exaaples of " inconsistencies" in AEC Construction Permit Application reviews:
"Although Part 100 was designed to apply to accident conditions, applicants are not, expected to use its limits as a tasis for 6esign even under acetraed accident conditions."
and
"... the AEC insists on 10 CFR 100 directed TID-14844 calculations while at the sc:nc time insisting tnat 10 CFR 100 does nat set limits on which th'e applicant can base his design. Yne applicant nust design for nuch.lcuer values against unspecifled limits."
Please infor a r.c if you would like any additional infornation or if you feel this n.atter should be scfieduled for discussion at a Subcomittec i
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'or full Comittec :ncetirg.
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M. W. Libarkin, Assistant Exem tive Director for Troject Review Attachxnts:
1)
!!. K. Udall ltr to M. A. Ros]cn dtd S/24/77 2)
P. L. Strauss ltr to M. K. Udall dtd 6/1/77 3)
M. K. Udall ltr to P. ~L.
Straucn dtd.6/7/77 cc ACPS MaAxrs l
- 1. F. Fraley t<
T. G. McCreless R. Fuller _
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