ML20127J281

Forwards Response to Concerns Re Emergency Planning at Facility Discussed During 850411 Limited Appearance Session. Principal Objective of Emergency Planning Is to Take Protective Action Before Public Exposed to Radiation

ML20127J281
Person / Time
Site:	Perry
Issue date:	06/17/1985
From:	Stefano J Office of Nuclear Reactor Regulation
To:	Bimber R AFFILIATION NOT ASSIGNED
References
NUDOCS 8506260539
Download: ML20127J281 (6)

Text

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9 m 17 E5 Docket No.: 50-440 Mr. Russell M. Bimber 10471 Prouty Road Painesville, Ohio 44077

Dear Mr. Bimber:

My letter to you dated May 24, 1985, advised that the Federal Emergency Manage-ment Agency (FEMA) would be responding to your concerns relative to the Perry plant Offsite Emergency Preparedness Plan, which you expressed during the Limited Appearance session at the Perry hearing on April 11, 1985.

This letter contains the NRC staff's responses to your concerns regarding emergency planning in general, which are enclosed.

If you have any further concerns or questions relative to the enclosed responses, please do not hesitate to contact me. If you have any questions on offsite emergency preparedness at Perry, it is suggested that you contact the FEMA Regional Office at:

Director, Federal Emergency Management Agency Region V 300 S. Wacker Drive - 24th Floor Chicago, Illinois 60606 Sincerely, John J. Stefano, Project Manager Licensing Branch No. 1 Division of Licensing

Enclosure:

NRC Responses to Concerns on Perry Plan Emergency Planning cc: See next page DISTRIBUTION:

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\...../ J W I 7 1985 Docket No.: 50-440 Mr. Russell M. Bimber 10471 Prouty Road Painesville, Ohio 44077

Dear Mr. Bimber:

My letter to 24, 1985, advised that the Federal Emergency Manage-ment Agency (you dated MayFEMA) would be responding to your concerns relative to plant Offsite Emergency Preparedness Plan, which you expressed during the L,imited Appearance session at the Perry liearing on April 11, 1985.

This letter contains the NRC staff's responses to your concerns regarding emergency planning in general, which are enclosed.

If you have any further concerns or questions relative to the enclosed responses, please do not hesitate to contact me. If you have any questions on offsite emergency preparedness at Perry, it is suggested that you contact the FEMA Regional Office at:

Director, Federal Emergency Management Agency Region V 300 S. Wacker Drive - 24th Floor Chicago, Illinois 60606 Sincerely, p

fQ / '{ L O John . Stefans froje Manager LiceningBranchfo.1 Divi 9onofjlinsing

Enclosure:

NRC Responses to Concerns on Perry Plan Emergency Planning cc: See next page t.

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i JW 17185 0028.0.0 Mr. Murray R. Edelman Perry Nuclear Power Plant The Cleveland Electric Units 1 and 2 Illuminating Company CC' Jay Silberg, Esq. Mr. Larry O. Beck Shaw, Pittman, & Trowbridge The Cleveland Electric 1800 M Street, N. W. Illuminating Company Washington, D. C. 20006 P. O. Box 97 E-210 Perry, Ohio 44081 Donald H. Hauser, Esq.

The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 Resident Inspector's Office U. S. Nuclear Regulatory Cwnission Permly at Center Road Perry, Ohio 44081 Reg'onal Administrator, Region III U. S. Nuclear Regulatory Connission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Donald T. Ezzone, Esq.

Assistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Ohio 44077 Ms. Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, Ohio 44060 Terry J. Lodge, Esq.

618 N. Michigan Street Suite 105 Toledo, Ohio 43624 John G. Cardinal Esq.

Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047

ENCLOSURE NRC Responses to Mr. Bimber's Concerns ,

on Perry Plant Emergency Planning EPA 520/1-75-001 allows the public to be exposed"to shole body Concern No. 1.

radiation fifty to a thousand times the limit for unrestricted areas set by i

prior Federal law.

Answer _:

First, the 100 millirems per week, not to exceed two millirems per hour, that you quoted from 10 CFR 20.105 pertains to permissible levels of radiation in unrestricted areas as a result of routine possession or use of radioactive materials and other sources of radiation. Second,theProtectiveActionGuides(PAGs)inthe Environmental Protection Agency's " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," ..

EPA-520/1-75-001, that you referenced pertain to the projected dose to individuals in the population which warrants taking some kind of The PAGs are not protective action (e.g., sheltering or evacuation).

to be construed as an acceptable dose. They are numerical values which serve as action points to initiate protective action so as to minimize risk from an event which is occurring or has already oc-curred. As stated in the EPA's manual, "The guides for the general population....were arrived at in consideration of protection of the public from the early effects of radiation and maintaining the delayed effects at a low probability." A principal objective of emergency planning is to take protective actions before any of the Onsite public is exposed to radiation during an emergency situation.

emergency response plans are developed for,1) early detection and

classification of the event, 2) prompt notification of State and local authorities and the public, 3) onsite response 50 mitigate the emergency'and 4) making protective action recomendations to appro-priate authorities.

The Perry Plant emergency plan has adopted the EPA PAGs for the plume exposure EPZ and the FDA guidelines for protection against ingestion of contamination (Ref. FDA Federal Register Notice, October 1982).

The NRC has reviewed and evaluated the Perry Plant emergency plan and

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finds that it meets the emergency planning standards and guidance of the NRC.

Concern No. 2. A serious discrepancy exists between the statement in NUREG-0884, Final Environmental Statement, page 5-16, that releases will remain well within the limits of 10 CFR 20, even under unusual operating conditions, and Perry's adoption of 1-5 Rem PAGs, on page 6-17 of its Final Safety Analysis Report.

t Answer: The Final Environmental Statement (FES), Section 5.9, " Radiological Impacts " pp. 5-15, 5-16, deals with the regulatory requirements that must be met in order to operate a nuclear power reactor. On page 5-16 of the FES, the staff states that, " Experience with the design, construction, and operation of nuclear power reactors indicates that compliance with these design objectives will keep average annual releases of radioactive material in affluents at small percentages of

3-the limits specified in 10 CFR 20 .... even under unus.ual operating conditions which may temporarily result in releases higher than such small percentages but still well within the limits specified in 10 CFR 20." In this instance, the staff is not referring to Site Area or General Emergency conditions when it talks about " unusual operat-ing conditions." Section 5.9.4.1 of the FES deals with plant acci-

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dents that result in a release of radioactive materials to the environment in excess of permissible limits for normal operation specified in 10 CFR 20 and 10 CFR 50, Appendix I.

As explained in our answer to your first concern regarding the PAGs, the PAGs of 1-5 Rem projected whole body exposure are not acceptable doses, nor are they dose limits used during routine operations. They are action levels which initiate predetermined protective actions for the public during emergency conditions.

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