ML20247F856
| ML20247F856 | |
| Person / Time | |
|---|---|
| Issue date: | 08/23/1989 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rosenberg W ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| NUDOCS 8909180294 | |
| Download: ML20247F856 (3) | |
Text
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NUCLEAR REGULATORY COMMISSION
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August'23, 1989
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- Mr. William G.1 Rosenberg.
Assistant Administrator for
. Air and Radiation Environmental. Protection Agency
'401 M Street, S.W..
Washington, D.C.
20460
Dear Mr.,
Rosenberg:
This. letter is in response to the May 26, 1989 request of Mr. J.. William Gunter for comments on the May 1989 draft of the Manual of Protective Action Guides
- andProtectiveActionsforNuclearIncidents(PAGmanual). The NRC staff has a.
keen interest in this document since'it is an inherent and vital part of our'
' regulatory program and, therefore, it directly affects our activities as well as those of our licensees : State, and loca1' authorities.: Therefore, I am Jwriting to you directly-to express the NRC staff concerns on this draft PAG
' manual.
The NRC' staff has been working in close cooperation with your staff _ over the past_several months and many of the: staff's concerns have been addressed in a reasonable and satisfactory manner.
In'particular, the document was revised to clarify the need to take protective actions based on reactor parameters under
- certain conditions. !However, we continue.to have serious concerns regarding
'this proposed guidance and wish to clearly convey the nature of our comments regarding the potential adverse impact should' implementation of the proposed
' draft be pursued.-
The Environmental Protection Agency (EPA) issued the current draft PAG manual in June 1980. This document provided PAGs'and implementation ~ guidance for exposures due to the plume or early phase of-a nuclear accident. ~ Guidance related to the intermediate or reentry / recovery phase (relocation PAGs) was not included at that time.
TheNRCregulations(1.0CFRPart50,AppendixE)referNRCreactorlicensees to Federal guidance contained in NUREG-0654 indicating that licensee and.
offsite authorities should establish appropriate procedures for recommending
'and implementing protective actions using the guidance in the draft EPA PAG i
l manual. As a result, this draft guidance has been incorporated in all licensee, State, and local' nuclear power plant emergency response plans and procedures 1
and has been used successfully in exercising these plans over the last several years. Thus,-at this time, the draft EPA PAG manual is essentially a " national standard" that is being routinely implemented by the entire U.S. response community.
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1 Mr. William G. Rosenberg l 1
As a result of a recent broad review by NRC offices, four fundamental concerns were identified in the May 1989 draft:
1.
The proposed PAGs would result in protective actions being taken at a lower plume exposure than existing PAGs. No need or justification for this significant change has been given, yet the implications and. impacts are significant. For example, the proposed PAGs call for protective action at 0.5 ren (from 1 rem) and evacuation is to take place based on 1remplumeexposure(fromthe1-5remrange). Our concern is that protective actions taken based upon such low values have not been justified and seem to be inconsistent with the potential risks associated with evacuation. Further, although the principles involved are similar to that of the international community, the proposed values are lower.
2.
The flexibility during the plume phase has been eliminated, and single values for specified protective actions have been included. 'The existing flexibility is an important feature of the existing guidance, and, while useful in most accidents, it might be crucial in the most severe accidents where the area at risk could extend beyond the 10-mile plume ex1osure pathway EPZ.
In these extreme cases, decisionmakers may need tie flexibility of sheltering populations projected to receive doses up to 5 rem in the interest of expediting the evacuation of persons at greater
- isk closer to the plant.
3.
Publication of this PAG manual for interim use will require substantial changes to existing licensee, State, and local emergency plans, including the requisite training, without significant additional protection of the public health and safety.
In addition, the proposed method of implement-ation indicating that the PAGs will be incorporated into plans when revised, would cause considerable confusion.
4 There is a lack of consideration for the impact of the PAGs on facilities other.than reactors.
Since this proposed EPA guidance has been in draft form for so many years, we can understand your desire in establishing formal PAGs as Presidential Guidance. We agree with that as an appropriate long-range goal for EPA.
However, it is our understanding that this draft is not being published for public comment preceding issuance as Presidential Guidance.
Rather, this will be another interim draft which will also not have the approval of the President.
It is rqy pcsition that publication of the PAG manual thould be delayed until a complete PAG manual can be published for public coment as part of the process for issuing the PAG manual as Presidential Guidance or that the PAG manual should be published for interim use without the proposed changes to the plume PAGs.
We have recently received a letttr from Mr. William Gunter of your staff, dated August 8, 1989, indicating that an additional 6-month comment period is l
being extended to all Federal Radiological Preparedness Coordinating Comittee 1
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.Mr. William G. Rosenberg '
members on applicability of the PAGs to nonreactor nuclear facilities. We l
sincerely hope that our. comments on the advisability of going forward with the L
revised PAGs for reactors as well will be factored into that review process.
k We appreciate the opportunity to comment that you and your staff have extended to this Agency during the development of this document. We will be forwarding more detailed comments and would be pleased to meet with you' at your
. convenience to discuss them.
If you should have any specific questions on this response, I ask that you contact Mr. Edward L. Jordan, Director, Office for Analysis and Evaluation of Operational Data, who has the lead technical responsibility for this document.
Sincerely, l
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J s M. Tay r eting Executive Director for Operations e
.