ML20136G275

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Comments on Final Amends to 10CFR50,App E Re Consideration of Earthquakes in Emergency Planning Per 850719 Memo.Fema Concerns as Discussed During 850723 Meeting Listed
ML20136G275
Person / Time
Issue date: 07/26/1985
From: Jordan E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Gillespie F
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20136D809 List:
References
FOIA-85-653 NUDOCS 8508060065
Download: ML20136G275 (2)


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JUL 2 61985 MEMORANDUM FOR: Francis P. Gillespie, Director Division of Risk Analyses and Operations Office of Nuclear Regulatory Research FROM: Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement

SUBJECT:

FINAL AMENDMENTS TO 10 CFR Plat 50, APPENDIX E; CONSIDERATION OF EARTHQUAKES IN EMERGENCY PLANNING IE offers the following comments on the Comission Paper forwarded by your July 19, 1985 memorandum:

1. A statement should be added to clarify that the requirements envisioned under Alternative 3 do not include detailed plant specific studies con-sidering the complicating effects of earthquakes or other natural phenomena on offsite emergency response capabilities. The " TERA" study completed for Diablo Canyon was such a study. The ACRS in its June 10, 1985 letter to the Comission, while essentially endorsing the staff position that only limited consideration of earthquakes is appropriate, cited the " TERA" study as meeting the intent of their comment that the local offsite authorities should have the benefit of studies indicating the types and potential loca-tions of damage to emergency travel routes. This was also discussed among the Commissioners and ACRS at the July 10, 1985 meeting. The staff's view is sorrewhat different and we should state explicitly that such a study is not required for other plants.
2. A better basis should be provided for the statement regarding minimal cost impact on licensees or state and local governments under " Cost Estimate" on page 7 of the Commission Paper. The Regulatory Analysis should contain this information. Also, delete the statement that FEMA's programs for Radiological Emergency Preparedness and Earthquake Hazards Reduction result in minimal cost impact for the new requirements, or explain how these pro-grams minimize the cost of the new requirements.

Contact:

Edward M. Podolak, IE

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OUl 2 61985 Francis P. Gillespie ' '

Additional'ly, ie met with FEMA on July 23, 1985 to obtain their views on the paper and Sheldon Schwartz discussed this issue with you. FEMA's concerns include:

1) the wording of the requirements and its impact on state and local governments and its own program, 2) the time frames for implementation, 3) the concern that a draft guidance memorandum should be included in the paper, and 4) the need for including additional information on existing FEMA programs for natural phenomena other than earthquakes. FEMA's legal staff is reviewing the Commission Paper.

Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement cc: R. W. Krimm, FEMA DISTRIBUTION RHVollmer, IE JGPartlow, IE BKGrimes, IE ELJordan, IE SASchwartz, IE KEPerkins, IE DBMatthews,IEp CRVan Niel, IF FKantor, IE EMPodolak, IE DCS DEPER RF EPB RF d ]

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