ML041210046
| ML041210046 | |
| Person / Time | |
|---|---|
| Issue date: | 08/02/2004 |
| From: | Reis T NRC/NRR/DIPM/IROB |
| To: | |
| moody r e nrr /eppo-b 415-1737 | |
| References | |
| RIS-04-013 | |
| Download: ML041210046 (6) | |
See also: RIS 2004-13
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
August 2, 2004
NRC REGULATORY ISSUE SUMMARY 2004-13
CONSIDERATION OF SHELTERING IN LICENSEES RANGE OF
PROTECTIVE ACTION RECOMMENDATIONS
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to clarify the regulatory requirement that licensees develop a range of protective actions that
includes sheltering for the public in the plume exposure pathway emergency planning zone
(EPZ). This RIS requires no action or written response on the part of addressees.
BACKGROUND INFORMATION
Section 50.47(b)(10) of Title 10 of the Code of Federal Regulations (CFR) states in part that
licensees are to develop a range of protective actions for the public in the plume exposure
pathway EPZ. In addition, 10 CFR 50.47(b)(10) states that in developing this range of
protective actions, consideration is to be given to sheltering, and that the guidelines for the
choice of protective actions be consistent with Federal guidance.
Following an inspection at Point Beach in August 2003 (ML040360104), the NRC staff
performed a review of licensee emergency plans, implementing procedures, and notification
forms to evaluate the extent licensees considered sheltering when recommending protective
actions to offsite organizations. During the review, the NRC staff has noticed that licensee
emergency plans, implementing procedures and notification forms consider sheltering in one of
three ways: (1) sheltering as an alternative to evacuation (shelter rather than evacuate),
(2) sheltering as a supplement to evacuation (evacuate downwind sectors and shelter the
remaining sectors until further instructions are provided), and (3) sheltering is not considered by
the licensee. The NRC staff has also noticed that some licensees have addressed sheltering
inconsistently in their emergency plan, implementing procedures, and notification forms. For
example, sheltering is considered as an alternative to evacuation in the emergency plan, but it
is not included as an option in the implementing procedures or on the notification form.
Page 2 of 4
DISCUSSION
The decision to recommend a protective action involves a judgment in which the radiation dose
avoidance provided by the protective action is weighed in the context of the risks involved in
taking the action. Since the decision will most likely be made under emergency conditions,
considerable planning is necessary to reduce the complexity of decisions required to effectively
protect the public at the time of an emergency.
Plant conditions are the major determining factors in developing early protective action
recommendations. To be most effective, protective actions (evacuation or shelter) need to be
taken before or shortly after the start of a major radioactive release to the atmosphere.
According to the original version of Appendix 1, Emergency Action Level Guidelines for Nuclear
Power Plants, in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of
Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power
Plants, the initial protective action for a General Emergency is to shelter the population close to
the plant while considering the advisability of evacuation. The guidance in the original version
of Appendix 1 further states that if core damage is in progress and containment failure is judged
to be imminent, shelter should be recommended for people in those areas that cannot be
evacuated before the plume arrives. Although the original guidance was never intended to
imply that the appropriate initial protective action for severe accidents was to only shelter the
population that is near the plant, it was not explicit on this point.
Subsequently, portions of Appendix 1 were revised in Supplement 3 Criteria for Protective
Action Recommendations for Severe Accidents, to NUREG-0654/FEMA-REP-1, Criteria for
Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in
Support of Nuclear Power Plants. Revised Appendix 1 states that for a General Emergency,
the preferred initial protective action is to evacuate immediately about two miles in all directions
from the plant and about five miles downwind, unless other conditions make evacuation
dangerous. Note 5 to Figure 1, Severe Damage or Loss of Control of Facility Public Protective
Actions, in Supplement 3, states that sheltering may be the appropriate action for controlled
releases of radioactive material from the containment, if there is assurance that the release is
short term (puff release) and the area near the plant cannot be evacuated before the plume
arrives.
10 CFR 50.47(b)(10) requires that the consideration of sheltering be included in the range of
protective action recommendations consistent with Federal guidance. In addition to the Federal
guidance discussed above, EPA 400-R-92-001, Manual of Protective Action Guides and
Protective Actions for Nuclear Accidents (EPA 400), dated May 1992, also contains information
on evacuation and sheltering. Section 5.5.3, General Guidance for Evacuation and Sheltering,
states that the process of evaluating, recommending, and implementing evacuation or shelter
for the public is far from an exact science, particularly in view of time constraints that prevent
thorough analysis at the time of an emergency. The effectiveness of evacuation and shelter
can be improved considerably by planning and testing. Also, EPA 400 states that sheltering
may be appropriate (when available) for areas not designated for immediate evacuation
because: 1) it positions the public to receive additional instructions; and 2) it may provide
protection equal to or greater than evacuation.
Page 3 of 4
SUMMARY OF ISSUE
The NRC staff has identified a generic misinterpretation of the regulatory requirement to include
sheltering in a licensees range of protective action recommendations (PARs) consistent with
Federal guidance. The NRC staff has found that some emergency plans specifically state that
the licensee will provide only evacuation as a PAR. In those cases, the appropriate protective
action recommendation consistent with Federal guidance may not be made to State and/or
local authorities. Even if the licensee has established an understanding with State and local
authorities not to recommend a sheltering protective action, 10 CFR 50.47(b)(10) still requires
that sheltering be considered in developing the range of protective action recommendations in
the licensees emergency plan.
Federal guidance states that sheltering may be the appropriate action for controlled releases of
radioactive material from the containment, if there is assurance that the release is short term
(puff release) and the area near the plant cannot be evacuated before the plume arrives.
Federal guidance also states that sheltering may be appropriate (when available) for areas not
designated for immediate evacuation because: 1) it positions the public to receive additional
instructions; and 2) it may provide protection equal to or greater than evacuation. Additionally,
a licensees emergency plan, implementing procedures, and notification forms need to include
the consideration of sheltering consistent with Federal guidance.
BACKFIT DISCUSSION
This RIS clarifies the regulatory requirements in 10 CFR 50.47(b)(10) related to the need for
licensees to develop a range of protective actions (including sheltering) for the public in the
plume exposure pathway EPZ. This RIS does not impose new or modified staff requirements
or uniquely prescribe a way to comply with the regulations, or require any action or written
response. Therefore, this RIS does not constitute a backfit under 10 CFR 50.109 and the staff
did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was not published in the Federal
Register because this RIS is informational and pertains to a staff position that does not
represent a departure from current regulatory practice.
Page 4 of 4
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not request any information collections and, therefore, is not subject to the
requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
If you have any questions about this matter, please contact Robert Kahler by telephone or by
e-mail at the numbers listed below.
/RA/
Terrence Reis, Acting Chief
Reactor Operations Branch
Division of Inspection Program Management
Office of Nuclear Reactor Regulation
Technical Contact: Robert Kahler, NSIR
(301) 415-2992
Email: rek@nrc.gov
Attachment: List of Recently Issued Regulatory Issue Summaries
- See previous concurrence
OFFICE EPPO:B TECH EDITOR EPPO:A EPPO:B OES:IROP:DIPM
NAME RMoody* PKleene* RKahler* EWeiss* CDPetrone*
DATE 04/25/2004 04/26//2004 05/06/2004 05/06/2004 07/20/2004
OFFICE OGC D:EPPO CRGR* OE PMAS
NAME MBupp* NMamish* DMcCain*
DATE 05/17/2004 05/20/2004 07/07/2004 06/14/2004 07/15/2004
OFFICE OCIO A:SC:OES:IROB:DIPM A:C:IROB:DIPM
NAME BShelton* AMcMurtray/Markley* TReis
DATE 07/15/2004 07/29/2004 08/02/2004
Attachment
Page 1 of 1
LIST OF RECENTLY ISSUED
NRC REGULATORY ISSUE SUMMARIES
_____________________________________________________________________________________
Regulatory Issue Date of
Summary No. Subject Issuance Issued to
_____________________________________________________________________________________
2004-12 Clarification on Use of Later 07/28/2004 All holders of operating licenses
Editions and Addenda to the for nuclear power reactors except
ASME OM Code and Section XI those who have permanently
ceased operations and have
certified that fuel has been
permanently removed from the
reactor vessel.
2003-18, Use of Nuclear Energy 07/13/2004 All holders of operating licenses
Supplement 1 INSTITUTE (NEI) 99-01, for nuclear power reactors and
Methodology for Development of licensees that have permanently
Emergency Action Levels, ceased operations and have
Revision 4, Dated January 2003 certified that fuel has been
permanently removed from the
reactor vessel.
2004-11 Supporting Information Associated 06/29/2004 All submitters of proprietary
with Requests For Withholding information to the Nuclear
Proprietary Information Regulatory Commission.
2004-10 Preparation And Scheduling of 06/14/2004 All holders of operating licenses
Operator Licensing Examinations for nuclear power reactors, except
those who have permanently
ceased operations and have
certified that fuel has been
permanently removed from the
reactor vessel.
2004-09 Status on Deferral of Active 06/07/2004 All holders of materials licenses for
Regulation of Ground-water uranium and thorium recovery
Protection At In Situ Leach facilities.
Uranium Extraction Facilities
2004-08 Results of the License Termination 05/28/2004 All holders of operating licenses
Rule Analysis for nuclear power reactors,
research and test reactors, as well
as decommissioning sites.
Note: NRC generic communications may be received in electronic format shortly after they are
issued by subscribing to the NRC listserver as follows:
To subscribe send an e-mail to <listproc@nrc.gov >, no subject, and the following
command in the message portion:
subscribe gc-nrr firstname lastname
______________________________________________________________________________________
OL = Operating License
CP = Construction Permit