ML20198R789
| ML20198R789 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, 05000000 |
| Issue date: | 01/27/1986 |
| From: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20198G688 | List:
|
| References | |
| NUDOCS 8602140323 | |
| Download: ML20198R789 (4) | |
Text
e HtO 6-p"""ug UNITED STATES b3 d,
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NUCLEAR REGULATORY COMMisslO j
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WASHINGTON, D. C. 20555
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JAN 2 71986 2
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- j MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation t.M).
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Dr.y FROM:
Robert B. Minogue, Director W.
Office of Nuclear Regulatory Research 4(
SUBJECT:
REDUCTION IN EMERGENCY PLANNING ZONE (EPZ) FOR CALVERT CLIFFS This is in response to your December 11, 1985, request for RES views on the application of Baltimore Gas and Electric Company (c)or an exemption to.th f
emergency p.l anning requirements of 10 CFR 50.47 (2) and Section I of 10 CFR 50 Appendix E to reduce the Calvert Cliffs plume exposure emergency planning zone from about 10 miles to 2 miles.
At the last RES quarterly review meeting it was agreed that a decision on this matter would be premature at this time and that no decision in this area would have a firm foundation until after NUREGs -0956 and -1150 are published.
Nevertheless, in response to your request we reconnend that the requested exemption be either denied at this time or that a decision be postponed until a generic rulemaking on the subject is completed in FY 1987 or FY 1988.
Our reasons for this position are multiple:
o NRC has under evaluation a petition for rulemaking (PRM-50-31) to expand the plume exposure EPZ to 20 miles.
o Although BG&E states that an exemption would relieve an unnecessary burden k
from Dorchester and St. Mary's counties, it does not provide any informa-
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tion to delineate or scope the burden to be relieved or the benefits to be derived from the requested exemption, o
Under the current emergency planning regulations, both FEMA and State and -
Iccal agencies must be involved in a decision regarding changes in EPZs.
Intervention and hearings are predictable upon the introduction of any change which would appear to reduce provisions for public health and safety, which a reduction in the EPZ would appear to be to many.
o The orderly progression of generic rulemaking on the emergency planning
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issue will serve the public better than a piecemeal, site-specific p
approach.
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Harold R. Denton 2
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BG&E does not make clear at all how a reduction in the plume exposure EPZ (from 10 miles) would relieve licensee, State and local emergency planning Q
burdens, if any, regarding the planning requirements for the 50-mile food and agricultural products EPZ.
In fact, in its application, BG&E ignores the relationship of the two EPZs.
o The technical basis provided by BG&E relies heavily on the NRC staff draft report, NUREG-0956; and the public comment period on that document was extended to January 7, 1986.
o One of the major admonitions in NUREG-0956 is to consider uncertainties in source terms in any regulatory application (p. xxiii), which BG8E
' d' ignored in its application.
You also requested views on several " interesting" legal and technical issues.
My brief response to these issues is:
o The public must be involved in major rule exemption or rulemaking decisions.
However, because of the broad policy implications of this action, the public would be better served with a generic rulemaking rather than a site-specific one.
o An alternative discussed in the past is reconsideration of various emergency preparedness provisions within the 10-mile EPZ, rather than a change in the 10-mile EPZ, per se.
Provisions for a graded emergency response plan would be a major example of such a change. The question of the role of site-specific versus generic information and decisions is a major policy question that should be resolved in rulemaking as opposed to site-specific litigation.
o RES would prefer an integrated approach looking at the source terms End risk from all of the six SARRP/NUREG-1150 reference plants to determine what the generic NRC positions should be and what, if any, plant-specific alternatives might exist.
To proceed first on a plant-specific basis could preclude a more rational, policy-level look at the problems, which could result in inadvertent, unfortunate decisions.
o Before we can discuss our opinions on " Technical Options," the important question "What are the problems?" must be answered.
It would be better policy to explore the problems first and then develop generic solutions.
,_____.___....__,______s
1
' Harold R. Denton 3
M 27g We understand you have sent a letter to BG&E to the effect that it is premature-to consider reducing the EPZ, and we strongly support that action.
/dLtV3M Robert B. Minogue, W Director Office of Nucleer Regulatory Research l
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