ML20149J851
| ML20149J851 | |
| Person / Time | |
|---|---|
| Issue date: | 05/02/1984 |
| From: | Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Bernero R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20149B526 | List: |
| References | |
| FOIA-87-743 NUDOCS 8802230250 | |
| Download: ML20149J851 (2) | |
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,,,,, AmuMGTON. TeXAe 70e11 ftay 2, 1984 MEMORANDUM FOR: Robert M. Bernero, Director, Accident So;rce Tern Office Of fice of Nuclear Regulatory Research FROM: Richard L. Rangart, Director. Division of Radiation Safety and Safeguards
SUBJECT:
PROPOSED AMENDMENTS TO 10 CFR PART 50, SICTIONS 50.45, 50.47, 50.54 AND APPENDIX E - AS WELL A$ 10 GN PARI 70; EMERGENCY PREPAREDNESS Region IV has reviewed the subject proposed revisions to ':mergenc) preparedness regulations as requested in your memorandum dated April 13, 1984. We concur with the ennreptual modifications surwarized on page 2 of your moorandum but have concerns related to the implementation nr justiff rAtton of two of the changes as irdicated in the following coments:
- 1. Graded response strategy - the discussion and supporting technical analysis do not clearly establish preselected ritt goals from which the protectiva action strategies are derived. Objectives of avoiding early fatalities and reduction of stochastic health effet.t> erv tuo vague, a more quantitative objective should be established.
Another factor in the analysis and potential implementation which should receive better definition is the concept of downwind sectors. The potential risk of receiving exposure in this area is also related to the method of designating the sectors to be evacuated. For example, the lowest risk might be associated with considering all sectors to be potentially downwind while the highest might be selection based on the sector with the projected downwind plume centerline. Other considerations might be based on whether or not a release is in progress. This is part of the risk assessment and should be addressed in the technical analysis
- 2. Elimination of unusual event - the proposed regulation wording does not appear to preclude the incorporation of unusual events into the three emergency classes. Also, if the unusual eventt are not considered to be "plant accidents" and the regulations are minircum requirements, there appears to be no requirement to delete the unusual event from plans and procedures.
The implementation of this regulation will involve signif t-cant revisions of federal, state, and licensee plans and procedures.
Because of this, there may be an incentive in finding alternate ways of impismenting this planning standard; therefore, all potential "loopholes" h uld be closed.
8802230250 000218 PDR FOIA SHOLLYB7-743 PDR h /V
4 Robert N. Bernero =2= Nay 2, 1984
- If there are any additional questions regarding these coments, we will be '
pleased to discuss them with you.
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b Richard L. 84ngart, Otr.ector Divtsien of Radiation Safety arid Safeguards cc: J. Davis, NMSS R. DeYoung, IE H. Denton, NRR G. Cunningham, ELO -
J. Felton, ORR ;
J. Fouchard, OPA ,
i' Regional Administrators RI, RII, Rl!!, and RV M. Jangochtan, ASTPO, RES i t
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