ML20112E265
| ML20112E265 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/20/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Hurwitz H AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20105B226 | List: |
| References | |
| FOIA-84-250, RTR-NUREG-0396, RTR-NUREG-396 NUDOCS 8501150076 | |
| Download: ML20112E265 (3) | |
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WASHINGTON, D. C. 20556 JUN 2 01983 M*. Henry Hurwitz, Jr.
827 Jamaica Road Schenectady, NY 12309
Dear Mr. Hurwitz:
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Thank you for your comments relating to emergency preparedness around nuclear power plants and, in particular, the Shoreham plant.
As you stated, I as the NRC representative on a panel convened by New York State Governor Cuomo.
This panel is chartered to explore the overall safety issue, the emergency prepared-ness issue, and other pertinent' issues pertaining to the Shoreham nuclear power plant.
I cannot agree with your contention that the NRC places undue emphasis on lower doses, and thus misdirects efforts and establishes poor precedent in a very severe accident.
In NRC report, NUREG-0396, entitled " Planning Basis for the Development of State and Local Government on Radiological Emergency Response Plans in Support of LWR Power Plants," which was published in December 1978, the NRC stated that a full spectrum of accident scenarios shall be considered for the~ development of emergency plans and that,."These very severe accidents have the potential for causing serious injuries and death.
Therefore, emergency
'p response for these conditions (accidents) must have as its'first priority the reduction of early severe health effects.
Studies have been performed which indicate that if emergency actions such as sheltering or evacuation were taken within about 10 miles of a power plant, there would be significant savings of early injuries and deaths from even the most ' severe' atmospheric release."
The NRC supports the principle, noted in existing NRC and EPA guidance, that acceptable values for emergency doses to the public under the actual conditions of a nuclear accident cannot be predetermined.
Rather, the objective is to minimize accidental doses to the extent practicable.
Furthermore, the emergency actions taken in any individual case must be based on the actual conditions that exist and are projected at the time of an accident.
For very serious accidents, predetermined protective actions would be taken if projected doses, at any place and time during an accident, equal or exceed the applicable Environmental Protection Agency's proposed Protective Action Guides (PAGs) (1 to 5 rem whole l
l body and 5 to 25 rem thyroid).
l The concept of Protective Action Guides was introduced into radiological emergency response planning to assist public health and other governmental authorities in deciding how much of a radiation hazard in the environment constitutes a basis for initiating emergency protective actions. These guides (PAGs) represent trigger or initiation levels, which warrant pre-selected protective actions for the public
- if the projected (future) dose to any individual in the absence of a protective T-.
action exceeds the PAG.
PAGs are defined or definable for all pathways of
.. radiation exposure to man'and are proposed as guidance to be used as a basis for taking action to minimize the impact on individuals.
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The EPA PAG values are based on many considerations, of which the major ones are:
1.
No detectable acute effects should occur.
2.
The risk of long-term effects to individuals should be minimal and in line with risks normally acceptable for an emergency.
3.
Risk of implementation should be less than the risk associated with the dose saved.
4.
The PAG should be reasonably implementable considering measurements required and time frames available.
5.
The costs associated with implementation should be within costs normally acceptable to society to avoid health risks of the same magnitude.
6.
PAG values should be expressed as a range so that expert judgment can be used in the face of unpredictable conditions that may accompany an emergency.
The nature of PAGs is such that they cannot be used to assure that a given level of exposure to individuals in the population will be prevented.
In any particular
~
response situation, a range of doses would be experienced, principally depending en the distance from the point of release.
Some of these doses may be well in excess of the PAG levels and clearly warrant the initiation of any feasible protective actions.
This does not mean, however, that doses above PAG 1evels can be prevented or that emergency response plans should have as-their objective preventing doses above the PAG 1evels.
Furthermore, PAGs represent only trigger levels and are not intended to represent acceptable dose levels.
PAGs are tools to be used as a decision aid in the actual response situation.
This response can include not only evacuation but also sheltering.
I trust that this information is useful to you in understanding NRC's position
.regarding Protective Action Guides and that it will alleviate your concerns.
Sincerely, (Signe:DWilliam J.Dircks W. J. Dircks Executive Director for Operations DISTRIBUTION:
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' F,qou ACTION CONTROL DATES CONTROL NO.
couaL oE m iNE 13134 Henry Hurwitz, Jr.
oATE OF OOCuuEuT Schenectady, NY wTEniu aEPLY
.3 r,Il 5/11/83 TO:
MVQ PREPARE FOR SIGNATURE RNAL REPLY OirCkS FILE LOCAh0N O$cui E oinEcTOa CTHER' DESCRIPTION
@ LETTER O uEuo O nEPoni O OTHER SPECIAL INSTRUCTIONS OR REMARKS Background with regard to New York State cttitudes concerning energy and ionizing radiation
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AS$10NED TO oATE
% TION RotmNG Hnoaue. RES for 5/17/83 Wrcks APPROP. ACTION
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Roe Rehn Stello DeYoung s
NRC FORM 232 EXECUTIVE DIRECTOR FOR OPERATIONS (m)
PRINCIPAL CORRESPONDENCE CONTROL x
I
-Letter from Hurvitz to Id. J. Eircks-Fage1 817 Jamaica Rd.,
Schenectady, NY 12389 May 11, '83 Mr. William J. Dircks E::ecutive Director for Operaticns U. S. Nuclear Regulators Commission Washington, DC. 28555
Dear Mr. Dircks:
Recent r.evs itens indicate that you are to be the f50 representatise en a panel convened by llev York State Gov. Cuomo to explcre safety and other issues pertaining to the Sh:reham plant. Fresumably, findings of the panel vill have a bearing en other llev York State nuclear pccer plants as well. It c: curs to me that it e,ay be helpful to you to have scos background with regard to New York State attitudes concerning energy and ionizing radiatien.
N The New V:rk State attituft torird energy, as exprested perticularly in the 1951 State Energy Master Flan 11, is that energy conservatien and energy geteration are 'enuivalent sources', and that the former is to be preferred. In the evidentiary hearings leading up to SEHF II, extensise svern and uncontroverted testimony was presented con:erning the well documented effect of residential energy conservation in increasir; pitlic exposure to ionizing radiaticn, particularly in6er ratn-222. In the absence of radon source term esasureesnts and mitigative actions, excess d se cctaitsents fres indoor reden in the range 18 to 188 rea car.not be encluded. The reaction cf the State Energy Office, as entodied in the Final Environmental !spact Statewnt for SE!? II, is that 'The likeliheed of such adrerse effects (from ionizing radiatica), hcwver, does not erpear to be sufficient to rarrant the abption of the reternendations made to rek:e su:h adverse offetts ' The SEMF 11 FEIS, including the explicit reje: tion of ar2 positive efforts whatscever to eenitor er aitigste the large potential public radiological d:se commitments from residential energy conservationi was kly endorsed b5 the New York State Energy Flanning Icard in its opinion and crder of March 25,1932. (Cf. Page 63, 64 of SEMP 11 Final Reporti March 'B2.) While the EFI did acknculed;e that i
further investigations of indoor air cuality tu the De;artsant of lhalth were warranted, no significant funding has been provided for such investigatiens. Furtheracte, M. David N
M
.