ML032120108

Federal Emergency Management Agency (FEMA) Response to 05/15/03 NRC Letter Issue Concerning Adequacy of Distribution & Tracking of Tone Alert Radios (Tars) for Arkansas Nuclear One

ML032120108
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/17/2003
From:	Lawrence Hammond Federal Emergency Management Agency
To:	Chamberlain D Division of Reactor Safety IV
References
Download: ML032120108 (2)

Text

a Federal Emergency Management Agency Region VI Federal Regional Center 800 North Loop 288 Denton, TX 76209-3606 June 17,2003 Mr. Dwight D. Chamberlain Director, Division of Reactor Safety Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlgton, TX 76011.4005

Dear Mr. Chamberlain:

This letter is in response to your letter dated May 15, 2003, which raised the issue concerning the adequacy of the distribution and tracking of tone alert radios (TARs) for Arkansas Nuclear One (ANO). The REP sA in FEMA Region VI and FEMA Headquarters have reviewed te matter and are in agreement that the emergency infrmation booklet (BB) alone does not provide satisthotoy administrative control of the TARs.

FEMA-REP-10, Section B.6.2.3 - Tone Alert Radios - states:

Tone alert radios should be offered to the public in geographical areas (where needed) and a 'best effort' attept must be made to place the radios. A record system (regste) containing an accurate li of addresses (names are optional) must be maintained for those geographical aas using the tone alert radios. The addresses of residents refuising tone alert radios should also be noted.

It apear that the Arkansas Department of Health (ADl), Nuclear Planning and Response Programs (NP&RP) office that is under cantract to ANO for emergency preparedness activities, obanged their method of control in 1999, and this change was not reviewed or approved by FEMA. The guidance contained inFEMA-REP-lO clearly equires he licensee to be proaotivIn prviding TARs and replm t batteries. The licensee must also maintain and update records of TARs, and providealaintenrce and testing procedures. The net effct of this change is a decreased level of assurance that everyone who need a TAR is aware that they are available. The change leaves the public on its own to discover the availability ofthe TARs.

Te November 2002 paper, "FEMA Review of Sigificant Changes to AN Systems," states, VPEMA Rule 44 CFR 350 establishes the policy and procedures for review and approval by FEMA of State and local emergency plans and preparedness for off0ite effects of a adiological eaergency that may occur at a commercial nuclear power facility.0' Furthemore, 44 CFR 350.5 requires that the means to provide early notification to the populace within the plume pathway Emergency PlanniWng Zone (WPZ) bc esblished. The paper also sates that;

Mr. Chamberlain June 17,2003 Page 2 In accordance with 44 CPR 350.14, a 'signifcant change' involves any change to State and local plans and preparedness that may affect its adequacy to protect public health and safety and must be processed and reviewed in the same manner as an initial plan submission. As It relates to an A&N system, a 'signiflcant change' Includes, a loss of administrative control of speeial alerting devices that brings into question whether affected population(s) can be notified in a timely maner.

Based on your inspector's report, one key aspect of administrative control; the recording and updating of records of those who have received or refued a TAR, has been lost Therefoe, FEMA is in agreemen with the NRC that in 1999, ADH-NP&RP changed procedures that PEMA approved in 1997. Based upon the information provided, PUMA's approval of the presen mehod would not be likey since the administrativcontrol is less than that described in FZM-IEP-10. FEMA regards this as a significant chage under 44 CFR. 350.14, which.

requires review and approval by FEMA prior to imple on.

TAR adminisave control must be consistent with FEMA-REP-10. The situation could be conected by a return to the same TAR administrative control by ADH-NP&RP that was.

accepted by FEMA in 1997. On June 3, 2003, ADH infomed FEMA Regioil VI at te had initiaed steps to add8s this issue and reinstate the administratv controls approved by PEMA in 1997. PEMA Region VI will require ADH to submit documnation verjing that adminirive controls as defined in te Design Report have beei reblished by Augut 1, 2003.

Since this issue has surfaced, FEMA Region VI REP staff will audit the adminIstrtve control records of indoor alerting systems at all REP communities in this Region to ensure this control is mainained. This a"dit will take place on a biennial basis during site visits.

Additonally, FEMA Region VI will strongly recommend more detailed indoor alting sytems reporting in the A ual Letow of Certification.

If you need further oaon, please contact me at (940) 898- 199 or the ANO Site Coordinator, Russell Bookser, at (940) 898-5336.

Sincerely, LisaR. Hamond RAC Chair cc: ADH - Bernard Bevill FEMA HQ - Vanessa Quinn