ML20248F252
| ML20248F252 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/1989 |
| From: | Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Gunter W ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| NUDOCS 8910060307 | |
| Download: ML20248F252 (4) | |
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September 18, 1989~
l Mr. William Gunter, Director Criteria and Standards Division (ANR-460) j Office of Radiation Programs i
Environmental Protection' Agency j,
- 401 M Street, S.W.
E Washington, D.C.
20460
.I
Dear Mr. Gunter:
1 It was beneficial to meet with you on August 29, 1989, to discuss issues relating to the May 1989 draft of the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (PAG Manual).
As a result of this f
meeting several issues were resolved.
We do, though, continue to have concerns regarding the fundamental issues outlined in the letter dated August 23, 1989, from Mr. James M. Taylor to Mr. William G. Rosenberg.
In addition, there are i
areas where additional dialog will be beneficial.
Mr. Thomas McKenna of my staff l
will be contacting your technical staff to schedule a meeting in the near future to discuss further the technical issues.
Enclosed is a brief summary of our discussions.
If you have any questions or comments on this summary, please give me a call.
I look forward to continuing interactions with the EPA on this vital matter.
1 1
Sincerely, Original Signed by:
E. L Jordan Edward L. Jordan, Director Office for Analysis and Evaluation
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of Operational Data
Enclosure:
Meeting Summary DISTRIBUTION:
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. ENC'OSURE L
MEETING
SUMMARY
The meeting was held at EPA's. request to discuss the fundamental concerns listed in the letter dated August 23, 1989, from Mr. James M. Taylor to Mr. William G.
Rosenberg'.
A summary of discussion is provided for each issue.
1.
The proposed protective action guide (PAG) would result in protective actior.s being taken at a. lower plume exposure than-existing PAGs.
The EPA stated that there was no intent to lower the PAGs from the current PAGs.
Table 2-1 now lists the lower end of the previous PAG (1 rem) for evacuation of the general population and previous PAG (5 rem) for special groups. gives the higher end -of the The footnotes 'and wording explaining the PAGs were intended to provide clarification, but not to make substantial changes to the PAGs.
The addition of a PAG of-0.5 rem for sheltering was made to provide clarification to the previous PAG Manual, which suggested sheltering at levels below the level-for evacuation.
i' The NRC stated that incorporation of the lower number only in the Table-was a de facto reduction in the PAG since previous implementation had-provided decision makers flexibility for action within the ranges provided.
The use of single numbers for sheltering and evacuation would likely result in the relatively rigid use of these numbers as trigger points for' action by licensees and government officials.
The NRC did-encourage the publication of those Chapters of the PAG Manual that have not been published previously, such as the recovery information.
The EPA and NRC agreed to have continuing dialog on the PAG issue, with no final decisions to be made for several months.
2.
Flexibility in plume phase has been eliminated.
The EPA stated that there was no intent to remove flexibility in implementation.
The single numbers were placed in the PAG table, but the footnotes and explanatory text were expanded to provide more guidance on other considerations appropriate to decision making, including other hazards and environmental conditions.
The NRC stated that, although several specific examples of how PAGs would be applied were provided, and proved useful, many other considerations not 3
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listed were valid in deciding when to implement protective actions.
The j
flexibility in the previous PAG table allowed decision makers more 1
flexibility in considering all aspects of protective action.
For example, decision makers may chose to delay evacuation, and thus increase potential dose to individual members of the public to above 1 rem, to account for l
approaching daylight or to await arrival of children at school during rush j
hour.
3.
Publication of the PAGs for interim use will require substantial changes to emergency plans and procedures and the method of implementation would j
i cause considerable confusion.
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c The' EPA stated that since the revised PAG Manual did not change the l-substance.of. plume PAGs, any. changes required by licensees, states and-local governments would be minor.
Also, the method of' implementation was 4
chosen to provide flexibility in application for users of the PAGs.
The NRC stated that there are large numbers of plans and. procedures that must be revised when considering licensee, state and local government
plans and procedures.
Also, the thousands of personnel using_the plans and procedures would have to be retrained.
The NRC saw no reason to incur this work when there did not appear to be any quantifiable improvement in safety.
Also, the NRC stated that'since a phased implementation might result in different PAGs for different plants within a state'or different PAGs for different plants within'a utility, it would be better that any changes-be made universally at the same time.
4.
There is lack of consideration for impact of PAGs on facilities other than reactors.
The EPA stated that an additional 6-month comment period would be provided for non-reactor facilities.
The NRC stated that we would be glad to work with the EPA as these drafts of PAGs for non reactor facilities are developed.
5.
Need for public comment.
The EPA agreed to. provide for' comment a copy of the current draft PAG:
Manual to the Conference of Radiation Control Program Directors (CRCPD),
NUMARC and representatives of fuel cycle facilities and other radioisotope users.
Several issues from the August 23, 1989, letter from Mr. Edward L. Jordan to Mr. William Gunter, were then discussed.
1.
Early phase defined as 4 days.
The EPA stated that there was no intent to lim't the use of.PAGs for workers to the first 4 days and that appropriate changes would be made
'to the PAG Manual.
2.
Emergency worker definition.
The EPA stated that the use would be revised, taking into consideration the various definitions used in publications of other federal agencies.
j 3.
Executive Summary.
The EPA agreed to develop such a summary.
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4.
Focus on Reactors.
The EPA agreed to develop necessary revisions over the next 6 months to accommodate non reactor facilities.
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The EPA stated that in discussions with representatives of.the CRCPD,.they-had determined that the presentation in the previous PAG Manuals was understandable.
The' EPA did agree to provide a copy'of the current draft PAG Manual to the CRCPD for comment.
6.
(Consideration of.0rgan Dose.
The EPA ~ stated that thefconsiderationHof prior l doses was an unnecessary-
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complication of little safety' significance relative to emerger.cy doses, t and that they did not. intend to incorporate considerationlof prior dose.
7 State and' local review.
The EPA agreed to provide'the draft PAG Manual to the CRCPD for review and:
comment.
8.
Public use of'KI.
The EPA agreed to clarify' wording so as not to imply a recommendation for use of K1 as ~a primary protective action.
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