ML20136G173
| ML20136G173 | |
| Person / Time | |
|---|---|
| Issue date: | 07/03/1985 |
| From: | Rowsome F Office of Nuclear Reactor Regulation |
| To: | Dircks W NRC |
| Shared Package | |
| ML20136D809 | List: |
| References | |
| FOIA-85-653 NUDOCS 8507180647 | |
| Download: ML20136G173 (4) | |
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l NOTE T0: William J. Dircks THRU: Harold R. Dent Themis P. Spe -
FROM: Frank H. Rowsome
SUBJECT:
EARTHQUAKE CONSIDERATIONS IN EMERGENCY PREPAREDNESS For your information, I have come up 'with three other ways a rule might be formulated to deal with this issue that are dissimilar to the five options suggested to you by DRA/RES. These appear in attachment 1. Also, for your information and as background material, I am enclosing a memo I wrote some months back on the evidence that emergency planning accomplishes no signif-icant risk reduction. It discusses some policy options suggested by this evidence. RES, IE, and NRR have seen this material before, but to my know-ledge no one has passed it on to you. Neither set of suggestions has, to my knowledge, been carefully evaluated. I do not wish to make a big issue of either attachment, but I think it would be worth the investment of your time to read them as background information for your future decisions on EP matters.
l l Frank H. Rowsome Attachments:
- 1. Options for Rulemaking to l Scope the Consideration of l
Earthquakes in EP l 2. Memo to H. Denton, et al, t
Re: Emergency Preparedness dated April 11, 1985 cc: R. Minogue, RES E. Jordan, IE G. Cunningham, ELD 9
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Options for Rulemaking to Scope the Consideration of Earthquakes in Emergency Preparedness W *p W 5%e of re #Seh ) $ a^n%bf H {ce W d e st e s~ besc Some alternatives in addition to those proposed by RES are these:
Y^ WM e 0 ,% c) 1 A. Relocation planning for accidents triggered by non-nuclear environmentaldisturbances,f [74 I a d
w The evidence suggests that any region-wide environmental disturbance that is of sufficient magnitude to rigger reactor accident would also interfere with anticipatory eva on and place competing demands upon emergency response personnel. Thus, planning for offsite emergency response to reactor accidents triggered by severe environmental phenomena should be limited to planning for relocation from hot spots of residual radiological contamination after plume passage. This approach to emergency response is generally expected to be more effective in limiting casualties under such conditions.
Licensees are required to have the capability to project and evaluate the health hazard in the affected offsite areas due to the reactor and to transmit this information to appropriate state and local authorities for their use in apportioning their resources among the competing demands for rescue work.
Pro: (1) Makes Emergency Preparedness (EP) more effective by, concentrating on the one potentially effective tactic.
(2) There is no need to sustain the awkward feature of limiting the consideration of earthquakes to the SSE.
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Con: (1) Might require reriotification and consnent.
(2) Would not pass a cost-benefit test.
B. Exclusion of Evacuation Planning in Favor of Relocation Planning for all reactor accidents. p g,4 f In light of the evidence that nticipatory evacuation is ineffectualjin reducing early casualties and d6e's~rict~sTg~nTfica'ntly t reduce the societal risk of latent casualties of reactor accidents, the NRC mandates that EP focus on relocation after plume passage rather than anticipatory evacuation. Priorities for relocation from contaminated areas should be based on realistic estimates of the local hazard and other competing demands on emergency response capabilities of responsible state and local authorities to protect public health and safety. Licensees are responsible for prcviding realistic prognoses and/or measurements of the radiation hazard offsite, and to inform local emergency response authorities of the contaminated areas and the urgency for relocation. That capacity alone is necessary and sufficient for compliance.
Pro: (1) Makes Emergency Plannin,g more effective at early fatality risk limitation.
(2) There is no need to single out reactor accidents triggered by regional non-nuclear disasters such as earthquakes, floods, or hurricanes.
h(3) EP would be far less burdensome under this rule. An OL would o longer require an evaluation of state and local p
a 1/ capabilities under this alternative, so the " Catch 22" features would disappear.
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d Con: (1) Relocation planning, though more nearly cost effective than evacuation planning, still does not pass a benefit / cost test. Some licensee costs would be entailed in the switchover from the present EP rules, though no more than the RES, Alternative 5, currently under development.
(2) Would require renotification and comment.
C. Good Neighbor Rule In light of the evidence that nuclear power plants pose very low risks of early casualties in the event of severe reactor accidents, and in light of the evidence _that anticipatory,__,
1 evacuation is ineffective in reducing _tle risk of fatalities in ,
any case, the NRC repeals its EP rules. In their stead, the NRC will pursue its Severe Accident Policy so as to further assure that nuclear power plants are safe enough to pose no undue risk j
without the assumption of offsite emergency preparedness or unusually prompt emergency response offsite.
Pro: Solves all the problems with over-regulation in the EP rules and regulations.
Con: This bets on the outcome of the Severe Accident Policy. Onsite accident management requirements and the screening of ors for outlier vulnerabilities are not yet in place or ready for
! rulemaking.
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