ML20289A632
| ML20289A632 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 10/15/2020 |
| From: | Young D Nuclear Energy Institute |
| To: | NRC/SECY |
| SECY/RAS | |
| References | |
| 85FR53690, NRC-2020-0155, PRM-50-123 | |
| Download: ML20289A632 (4) | |
Text
PRM-50-123 1 85 FR 53690 From: YOUNG, David To: RulemakingComments Resource Cc: Brock, Kathryn
Subject:
[External_Sender] Comments on Petition for Rulemaking, Public Protective Actions During a General Emergency
[Docket No. PRM-50-123; NRC-2020-0155]
Date: Thursday, October 15, 2020 11:43:20 AM Attachments: Comments on Petition for Rulemaking, Public Protective Actions During a General Emergency [Docket No.
PRM-50-123; NRC-2020-0155].pdf October 15, 2020 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
Subject:
Comments on Petition for Rulemaking, Public Protective Actions During a General Emergency [Docket No. PRM-50-123; NRC-2020-0155]
To the Rulemakings and Adjudications Staff:
[1]
The Nuclear Energy Institute (NEI) appreciates the opportunity to provide comments to the U.S. Nuclear Regulatory Commission (NRC) on the subject Petition for Rulemaking (PRM). As an overarching comment, we support changes to ensure that the actions taken to protect the public in the event of a General Emergency will most likely do more good than harm considering the potential health hazard of both radiation exposure and protective actions. The proposed changes should be based on NRC-directed studies performed to better quantify the current understanding of health risks of protective actions and associated dislocations.
As stated in the PRM, we encourage the NRC to create a risk-informed basis for protective action strategies. This includes revisiting the agencys use of the Early Phase dose criteria presented in
[2]
the PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents, published by the U.S. Environmental Protection Agency (EPA), to inform protective action decision-making guidance. The PRM presents an opportunity to assess the recommended dose limits in light of the lessons learned from actual events and remove conservative assumptions that may cause more harm than good.
Should the NRC elect to move forward with a plan to address this PRM, we recommend that the following points be considered.
- 1. Under current guidance, the licensee of a power reactor facility must transmit protective action recommendations to offsite response organizations (OROs) within 15 minutes of a General Emergency declaration, and the OROs have another 15 minutes to determine protective actions for the public. Revised protective action strategies should be structured to meet these time-based goals or, alternatively, the goals should be changed if additional decision-making time is warranted in the interest of making better risk-informed decisions
for protection of the public.
- 2. The development of new protective action strategies and decision-making aids will necessitate extensive stakeholder input and reviews; in addition to the NRC, key stakeholders should include licensees, OROs, the Conference of Radiation Control Program Directors (CRCPD), and the U.S. Federal Emergency Management Agency (FEMA).
- 3. The eventual requirements related to implementation of new protective action strategies should allow adequate time for budgeting and completion of procedure and dose projection software changes, and training by both licensees and OROs.
- 4. Finally, the NRC staff should consider potential improvements to the regulations and guidance that govern the consequence-based EP frameworks for the various types of facilities licensed by the NRC. For example, if the current EPA PAG dose limit will be replaced with a more appropriate dose limit, then changes to the criteria for determining the size of Emergency Planning Zones may also be warranted.
In closing, we encourage the NRC staff to undertake a rulemaking that considers the issues raised by a PRM.
Should you require additional information, please contact me at (202) 739-8127 or dly@nei.org.
Sincerely, David L. Young c: Ms. Kathryn Brock, NSIR/DPR, NRC
[1]
The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
[2]
The document is available here.
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DAVID YOUNG Technical Advisor, Nuclear Security and Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8127 dly@nei.org nei.org October 15, 2020 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
Subject:
Comments on Petition for Rulemaking, Public Protective Actions During a General Emergency
[Docket No. PRM-50-123; NRC-2020-0155]
To the Rulemakings and Adjudications Staff:
The Nuclear Energy Institute (NEI) 1 appreciates the opportunity to provide comments to the U.S. Nuclear Regulatory Commission (NRC) on the subject Petition for Rulemaking (PRM). As an overarching comment, we support changes to ensure that the actions taken to protect the public in the event of a General Emergency will most likely do more good than harm considering the potential health hazard of both radiation exposure and protective actions. The proposed changes should be based on NRC-directed studies performed to better quantify the current understanding of health risks of protective actions and associated dislocations.
As stated in the PRM, we encourage the NRC to create a risk-informed basis for protective action strategies.
This includes revisiting the agencys use of the Early Phase dose criteria presented in the PAG Manual:
Protective Action Guides and Planning Guidance for Radiological Incidents, 2 published by the U.S.
Environmental Protection Agency (EPA), to inform protective action decision-making guidance. The PRM presents an opportunity to assess the recommended dose limits in light of the lessons learned from actual events and remove conservative assumptions that may cause more harm than good.
1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
2 The document is available here.
Rulemakings and Adjudications Staff October 15, 2020 Page 2 Should the NRC elect to move forward with a plan to address this PRM, we recommend that the following points be considered.
- 1. Under current guidance, the licensee of a power reactor facility must transmit protective action recommendations to offsite response organizations (OROs) within 15 minutes of a General Emergency declaration, and the OROs have another 15 minutes to determine protective actions for the public. Revised protective action strategies should be structured to meet these time-based goals or, alternatively, the goals should be changed if additional decision-making time is warranted in the interest of making better risk-informed decisions for protection of the public.
- 2. The development of new protective action strategies and decision-making aids will necessitate extensive stakeholder input and reviews; in addition to the NRC, key stakeholders should include licensees, OROs, the Conference of Radiation Control Program Directors (CRCPD), and the U.S.
Federal Emergency Management Agency (FEMA).
- 3. The eventual requirements related to implementation of new protective action strategies should allow adequate time for budgeting and completion of procedure and dose projection software changes, and training by both licensees and OROs.
- 4. Finally, the NRC staff should consider potential improvements to the regulations and guidance that govern the consequence-based EP frameworks for the various types of facilities licensed by the NRC.
For example, if the current EPA PAG dose limit will be replaced with a more appropriate dose limit, then changes to the criteria for determining the size of Emergency Planning Zones may also be warranted.
In closing, we encourage the NRC staff to undertake a rulemaking that considers the issues raised by a PRM.
Should you require additional information, please contact me at (202) 739-8127 or dly@nei.org.
Sincerely, David L. Young c: Ms. Kathryn Brock, NSIR/DPR, NRC