ML20197K078
| ML20197K078 | |
| Person / Time | |
|---|---|
| Issue date: | 07/17/1985 |
| From: | Ward D Advisory Committee on Reactor Safeguards |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1140, NUDOCS 8508010702 | |
| Download: ML20197K078 (2) | |
Text
(Jetsf-/&i UNITED STATES
/
NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS o,
- ..... '#g WASHINGTON, D. C. 20566 July 17, 1985 Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Comission Washingtcn, D.C. 20555
Dear Dr. Palladino:
SUB. C : ACRS COPNENTS ON EMERGENCY PREPAREDNESS FOR FUEL CYCLE AND OTHER RADI0 ACTIVE MATERIAL LICENSEES During its 303rd meeting, July 11-13, 1985, the Advisory Comittee on Reactor Safeguards met with the NRC Staff to review the proposed rule on
" Emergency Preparedness for Fuel C Licensees" (10 CFR 30, 40, and 70)ycle and Other Radioactive Material This was also a subject for dis-cussion during a meeting of our Subcommittees on Waste Management and Site Evaluation on June 19, 1985.
The Committee also had the benefit of the documents referenced.
As a result of these discussions, we commend the NRC Staff for its careful and detailed analysis of emergency preparedness requirements for fuel cycle and other radioactive material licensees.
We believe that the supporting document, "A Regulatory Analysis on Emergency Prepared-ness for Fuel Cycle and Other Radioactive Material Licensees" (NUREG-1140), will be a valuable resource to licensees.
However, we have serious reservations about the implementation of the proposed rule on the grounds that problems of potential accidents may already be adequately covered by existing plans -- for example, by the licensee's Radiological Contingency Plans required by the NRC, and by the National Contingency Plans required under the Resource Conservation and Recovery Act of 1976.
We note also that the need for a fonnal emergency plan is made question-able by data covering some 500,000 Ifcensee years of experience which show that, although some 5,000 accidents have a: curred, none has re-sulted in a dose to off-site members of the public exceeding one percent of the one rem effective dose equivalent suggested in the proposed rule.
This experience is supported by the NRC Staff analyses showing that the one rem dose is attained only when very conservative approaches are used l
in estimating off-site doses for a range of accident scenarios.
On the basis of these observations, we recomend that the proposed rule not be promulgated.
Where the analyses show that accidents at a few selected facilities (such as UF and fuel fabrication plants) could be 6
g%,a,w,1x~m' ' -
p
~_.,f 5'bd6 f 070% '/W w
4...
y %_-)f W-L WO
Honorable Nunzio J. Palladino July 17, 1985 significant, perhaps some increase in emergency planning may be required on an individual plant and site-specific basis.
Overall, however, we see no need for the proposed rule.
Sincerely, O
f01 f
VG,1 y
i David A. Ward Chairman
References:
1.
Nuclear Regulatory Commission, Proposed Rule,10 CFR Pt.rts 30, 40, and 70, " Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," draft dated June 12, 1985 2.
Nuclear Regulatory Connission, NUREG-1140,
Subject:
A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radio-active Material Licensees, dated June, 1985, l
l i
l l
l l
. -.