ML041540163

Response to NEI White Paper on the Range of Protective Actions for Nuclear Power Incidents

ML041540163
Person / Time
Issue date:	06/17/2004
From:	Nader Mamish Office of Nuclear Security and Incident Response
To:	Alexis Nelson Nuclear Energy Institute
Moody R EPPO 415-1737
References
Download: ML041540163 (2)

Text

June 17, 2004 Mr. Alan Nelson Chief, Emergency Preparedness Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

Dear Mr. Nelson:

Thank you for sending the white paper titled "Range of Protective Actions for Nuclear Power Incidents", that was attached to your letter dated May 19, 2004. We appreciate the industrys effort to clarify the range of early phase protective actions that may be used for nuclear power.

After reviewing the white paper, we note that it includes some discussion of sheltering as an alternative to evacuation, for special populations, and in the event there are impediments to evacuation.

We disagree with the paper recommendation that sheltering "may" or "should" be incorporated in the licensees range of protective actions. 10 CFR 50.47(b)(10) requires that sheltering be considered in a licensees range of protective action recommendations (PARs). The staff has found that many emergency plans specifically state that the licensee will provide only evacuation as a PAR. Therefore, the staff is drafting a Regulatory Information Summary (RIS) to clarify the regulatory requirements in 10 CFR 50.47(b)(10) to correct this misinterpretation.

Nevertheless, there is much value in the white paper that can be used to improve guidance in the PAR area. We are presently in the process of initiating a contract to perform a review of Supplement 3, "Criteria for Protective Action Recommendations for Severe Accidents" to NUREG-0654/FEMA-REP-1, Revision 1. We will share the white paper with the contractor once the contract has been signed.

Should you have any questions regarding this letter, please feel free to contact me, or Robert Kahler, of my staff at (301) 415-1086.

Sincerely,

/RA/

Nader L. Mamish, Director Emergency Preparedness Directorate Office of Nuclear Security and Incident Response

Mr. Alan Nelson Chief, Emergency Preparedness Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

Dear Mr. Nelson:

Thank you for sending the white paper titled "Range of Protective Actions for Nuclear Power Incidents", that was attached to your letter dated May 19, 2004. We appreciate the industrys effort to clarify the range of early phase protective actions that may be used for nuclear power.

After reviewing the white paper, we note that it includes some discussion of sheltering as an alternative to evacuation, for special populations, and in the event there are impediments to evacuation.

We disagree with the paper recommendation that sheltering "may" or "should" be incorporated in the licensees range of protective actions. 10 CFR 50.47(b)(10) requires that sheltering be considered in a licensees range of protective action recommendations (PARs). The staff has found that many emergency plans specifically state that the licensee will provide only evacuation as a PAR. Therefore, the staff is drafting a Regulatory Information Summary (RIS) to clarify the regulatory requirements in 10 CFR 50.47(b)(10) to correct this misinterpretation.

Nevertheless, there is much value in the white paper that can be used to improve guidance in the PAR area. We are presently in the process of initiating a contract to perform a review of Supplement 3, "Criteria for Protective Action Recommendations for Severe Accidents" to NUREG-0654/FEMA-REP-1, Revision 1. We will share the white paper with the contractor once the contract has been signed.

Should you have any questions regarding this letter, please feel free to contact me, or Robert Kahler, of my staff at (301) 415-1086.

Sincerely,

/RA/

Nader L. Mamish, Director Emergency Preparedness Directorate Office of Nuclear Security and Incident Response DISTRIBUTION:

EPPO Reading File R. Kahler R.Moody T. McGinty E. Weiss Accession Number:ML041540163 OFFICE NRR/EPPO-B NRR/EPPO-A NRR/EPPO-A NRR/EPPO-B OGC NRR/EPPO NAME RMoody* RKahler* TMcGinty* EWeiss* TSmith NMamish DATE 06/2/2004 06/3/2004 06/7/2004 06/8/2004 06/14/04 06/17/04 OFFICIAL RECORD COPY