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Review of the Emergency Planning Sensitivity

Project Title: Study for Seabrook

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In the event a subcon

BNL does not intend to subcontract any portion of this work. tract is anticipated, BNL will notify MRC before it is initiated.

8. NEW CAPITAL EQUIPMENT REQUIRED

None.

9. SPECIAL FACILITIES REQUIRED

None.

10. CONFLICT OF INTEREST INFORMATION

There are neither significant contractual nor organizational relationships of the Department of Energy, BNL and employees, or expected subcontractors or consultants on this proposal, with industries regulated by the NRC and suppliers thereof that give rise to an apparent or actual conflict of interest.

11. EXPECTED CLASSIFICATION OR SENSITIVITY

This is an unclassified program. Safeguarde, proprietary, or other sensitive information is not involved.

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I have reviewed your proposed memo to H. Denton on the Seabrook review and provided comments in the form of markups to V. Noonan on August 8. It is important to decide what direction NRC is going to take on this issue before a detailed technical review can start. A decision chart set up in the form of three questions is attached for your consideration. I would recommend that you assemble a small group to assess the potential approaches to the review. Four individuals, one from each, PWRL, USRO, IE and OGC, could do the job in about two weeks. Our representative is Len Soffer, please feel free to contact him directly.

CC: H. Denton

Themis Speis

Potential Approaches to the Review of the Seabrook
EPZ Submittal

1. Assuming that all technical information received from Seabrook is correct, can NRC reduce the Seabrook EPL or evacuation zone below the 10 mile limit under current regulations and established regulatory practice?

2.

If answer is No, go to Q-2.

If answer is Yes:

What information is important for the decision?
What additional information is needed from PSNH?

Can NRC use a risk based criteria to justify a reduction in EPZ or evacuation zone for Seabrook without "rulemaking" or granting an exemption?

If answer is No
or go to -3.

If answer is Yes:

Seabrook should either join the ongoing rulemaking

What information is important for the decision?

What additional information is needed for PSNH?

3. What basis could NRC have for granting an exemption from existing emergency planning requirements for Seabrook?

a.) Is the Seabrook plant significantly different from other PWRS with large dry containments with respect to Emergency Planning requirements?

If answer is No, go to Q-3b.

If answer is Yes:

What information is important for the decision?

What additional information is needed from PSNH?

b.) Is there an "immediate need" for Seabrook, that would justify exempting it from current EPZ requirements while the rule change is underway?

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