ML101740073

Comment (22) of D.J. Bannister on Behalf of Omaha Public Power District on NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3, Guidance for Protective Action Recommendations for General Emergencies.

ML101740073
Person / Time
Site:	Fort Calhoun
Issue date:	06/21/2010
From:	Bannister D J Omaha Public Power District
To:	Lesar M T Rulemaking, Directives, and Editing Branch
References
75FR10524 00022, NRC-2010-0080
Download: ML101740073 (2)

Text

el Omaha Public Power DisAict 444 South 16'h Street Mall Omaha, NE 68102-2247 K3/42f ~-T FT1 C/13 June 21, 2010 LIC-10-0037 Michael T. Lesar Chief, Rulemaking, Announcements and Directives Branch (RDB)Division of Administrative Services, Office of Administration Mail Stop: TWB-05-BO1 M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

1. Docket No. 50-285 2. Federal Register Notice, "NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3, Guidance for Protective Action Recommendations for General Emergencies; Draft for Comment," (75 FR 10524)Comments on NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3,"Guidance for Protective Action Recommendations for General Emergencies," Docket ID NRC-2010-0080 In Reference 2, the Nuclear Regulatory Commission (NRC) requested public comment on draft NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3, "Guidance for Protective Action Recommendations for General Emergencies." Accordingly, the Omaha Public Power District (OPPD) provides the following comments: 1. Page 3 states that Supplement 3 is the guidance to follow to meet the requirements of 10 CFR 50.47(b)(10).

However, it also states that by issuing this guidance, the NRC does not intend to affect the protective action guidelines developed and promulgated by the U.S. Environmental Protection Agency (EPA).The EPA protective action guides remain the appropriate Federal guidance on radiological criteria for consideration of protective actions. OPPD's position is that it would be -better to incorporate both sets of guidance into a single document to prevent confusion and potential regulatory issues.2. Page 11 discusses the radiological assessment based Protective Action Recommendation (PAR) but does not state what source term is considered sufficient to cause exposures in excess of EPA guidelines.

Previous guidance-Yinployment with Equal Opportunity 76 -,t~2~j i < .U. S. Nuclear Regulatory Commission LIC-10-0037 Page 2 suggested a source term of > 20% fuel clad damage was sufficient; however, recent NRC findings suggest this is not the case.3. The current structure of radiological preparedness has worked well for the utilities, states and counties of Nebraska and Iowa. The proposed changes to PAR guidance would cause these entities to incur significant costs without significantly improving public safety.No commitments to the NRC are made in this letter.If you have any questions or require additional information, please contact Mr. Bill R.Hansher at (402) 533-6894.Sincerely, D. J. Bannister Vice President-Nuclear DJB/SWG/mle c: E. E. Collins, NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C; Kirkland, NRC Senior Resident Inspector