ML20236F190
| ML20236F190 | |
| Person / Time | |
|---|---|
| Issue date: | 10/21/1987 |
| From: | Congel F Office of Nuclear Reactor Regulation |
| To: | Krimm R Federal Emergency Management Agency |
| Shared Package | |
| ML20236F162 | List: |
| References | |
| FRN-52FR6980, RULE-PR-50 NUDOCS 8711020038 | |
| Download: ML20236F190 (4) | |
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NUCLE AR REGUL A10RY COMMISSION -
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W ASHi*<G ion, D. C. 20550 '
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October 21,1987
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MEMORANDUM' FOR:: Richard W. Krinen Assistant Associate Ofrector Of fice:of Natural and Technological.
Ifarards Programs j
Tederal Emergency 4'nagement Agency
.FROM:
Frank J. Congel, Director-Division of Radiation Protection I
snd Emergency Preparedness Of fice of Nuclear 'leactor Regulation 4
SUBJECT:
DEVELOPMENT OF UTILITY Of fSITE PLAN EVALUATION CRITERIA i
reached at' the October 15 1987/ meeting This responds to the. understanding d in Dave -McLoughli between ~ FEMA and NRC, and refitete memorandum to. Victor Stello.
We agreed ' that. the NRC would provide written' l
instructions which state specifically the assumptions upon which.utf11ty off-l site plan reviews would be conducted by FEMA.
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I In developing evaluation criteria and in reviewing utility sponsorad offsite state emergency response plans, FEMA should assume that in an actual eme and local officials will.(1) h
-and safety of the p(ubHe, (2)1xerme their best e cooperate with the utfif ty and follow the utilityc(
offsite plan, and 3): apply resources that are within the general capabilities. !
of state and loce1 ~ governments to irrplement those portions of the utility.
offsite plan where state or local response is necessary.
q As we further agreed, any FEMA findings on the adequacy of uti 1
plans will necessarily include the caveat that FEM was requested by the NRC to use the above assumptions in evaluating a utfif ty offsite plan.
s-Trant J. Congel, Of rector l
Divuion of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
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t CONTACT: Edward M. Podolak, Jr., NRR 492-7290 8711020038 871027l
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OR. ROSS' COMr.ENTS-i j
Proposal:
l Allow issuance of full-power' license even when there is lack of cooperation by State and/or local governtnents in development or implementation of offsite EP.
l Provided that_:
I non-compliance could be remedial or adequately compensated by re 1)
State or local government cooperation, d sustained effort by applicant to get cooperation, 2) good faith an I
offsite EP includes a11' effective measures to coj 1
3) response,and J
i State or local government have baen provided with copies of the pla A) been assured applicant is ready to cooperate.
Special emphasis 1
1)
Policy--not new science
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Policy issue--Is it essential that we find tht.t some protective measures I
2)
FPL7 wi,1_1, he taken, as part of o
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_i 1
3)
Minimun change 4)
Informal rulemaking i
5)
Get FEMA views during comment period.
l Existing 10 CFR 50.47 Para. (c)(1) has some loopholas--
" deficiencies...not significant"
" adequate unknown compensating actions" "other compelling r easons"
,e Huggets from 50.47 and Appendix E' j
'" adequate protective measures can and will be taken" (a)(1)'
whether State and local' emergency plans as adequate responsibility of State and local organizations assigned.
FEMA:
(a)(?)
Principle response organization has staff to respond..
(b)(1) procedures for notification of S&L officials established.
(b)(S)
(b)(6) exercises conducted Appendix E Identification of State,' local officials j'
A.8 Assessment actions--agreed on by State and. Local P
Notification D
Administrative and Physical means 1.
l S&L will determine whether to activate Notify St,L in - 15 min.
2.
entire system 3.-
Exercise with SAL StL in remedial exercise.
4.
I Dose Perspective (see figures) l for 557-1, w/o evacuation, can get 200 rem at S miles in 2-3 h For SST-1, in shelter, at 5 miles, probability of exceedinl 50 percent of exceeding ?00 rem at 3 miles.
Probability is percent.
At Zion, at 3 miles, probability is a 50 percent of exceed Could reduce toa10 percent w/ shelter, essentially zero Q'
normal activity.
with prompt evacuation.
EP can reduce 70 rem whole dose in plume.
(*
At Surry, at 5 miles, get this-0, i
Observation, conclusion See p.14 of paper; the new proposed Para. 6 to Sectio Part 50 does not clean up the other portions of Appendix E A,B.D.forexample).
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i states'that adequate offsite emergency planning is
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-p. 5.of paper:
1 feasible, and all ~other aspects of foregoing criteria are satisfied; " hat Jdoes'the mean about: Appendix Et l
- p. 7 of paper:. states.that regulatory flexibility is warranted for-
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EP.-less.important than ECCS (e.g.)
This is-No minimum dose savings ;is established as' standard for EP.However, the consistent with the. bottom of 'p. - ? of. 0396.
- p. 5 should be' considered. 'The recomended planning basis (p.11-13) should be re-read.
Emphasis on pre-detennined action, q
o The' principle purpose of the plume exposure EPZLis to provide for substantial reduction in early severe health effects (063 p..'10).
-Implies mutually supportive S&L planning (p.16).
~ Local government. plans are particularly important (p.17)).
Plans. should -
not be developed is. isolation (p. 20.) Weaknesses can be compensated (p.
20).
f Advance arrangements with S&L by utility is necessary (p. ??).
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. Response organizations which receive notifications should have authority i
and capability to take.imediate predetermined actions, Utility cannot compensate for lack of predeterminal actions by S&L.
n Little on prudent and feasible dose. reduction can be achieved by utility along; nearby. residents could shelter' (not too effective fe3 mi., gets better w/ distance) but evacuat'jois unthinkable by utility alone.
.p.10, bottom para, of paper, speaks of best-efforts utility plan for l
possible S&t. cooperation; surely this is speculatative.
.S umary:
y.
Doses near-in (f3 miles or so) can be life-threatening No predetermined actions can be assumed by utility alone, thus no l
o projected dose savings of significance can be assured Fabric of 0654 is woven Appendix E H died with inconsistencies This action should not be approved, unless the utility agrees to an i
analysis that prompt notification directly to affected people (as detennined by new risk info., keyhole within a few miles), will result in p(rompt evacuatT6n, as directed by people under cont probably not feasible).
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