ML19207B771
| ML19207B771 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/11/1979 |
| From: | Kearns J CALIFORNIA, STATE OF |
| To: | Salomon S NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| RTR-NUREG-0553, RTR-NUREG-553 NUDOCS 7909050251 | |
| Download: ML19207B771 (5) | |
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$ TATE CF CAUFoRNIA EDMUND G. BRCWN JR., Govemor OFFICE OF EMERGENCY SERVICES PCST OFFICE box 9577 SACRAMENTO. CAUFoRNIA 93823 (916) 421-4990 June 11, 1979 Stephen N. Salomon Office of State Programs U.
S. Nuclear Regulatory Commission Mail Stop 7109 Washington, D. C.
20555
Dear Steve:
Attached are specific comments dealing with "BEYOND DEFENSE-IN-DEPTH", NUREG-0553. I realize my comments are quite late, nevertheless, I did want to share them with you.
In addition to the specific comments, I have some general observations regard-ing the Executive Sn'= ry, pages I.l. and I.2.
A.
I am confused why we would spend S35 million for achieving NRC concurrence while simultaneously spending $27 million for implementing the EPZ concept for most sites. Are these mutually exclusive events? I would imagine our total planning effort should be directed to the EPZ concept and not simply to get NRC concurrence.
3.
The 35 millnn for 10 Office of State Programs, NRC consultants is only for 5 years and et for the period of 1980-2000.
I know this is a matter of semantics, but it should be made clear. In fact, many of the costs included in the S147 million will be expended in the first few years with only main-tenance costs during the remainder of the 20-year period.
C.
With regard to 100% funding of local gover. ment officials, are the $40 million FEMA funds to be distributed over the 20-year period; if not, over what period?
If its over the 20 years, this is only an increase of 32 million per year.
This won't get us very much even though you propose a salary of about $20,000 per year for these individuals, whereas 5100,000 is proposed for the 10 NRC consultants. You reference this 100% funding to all impacted jurisdictions within the lO-mile EPZ without identifying hcw many jurisdictions would be involved. Also, if FEMA is going to provide 100% for personnel within the 10-mile EP2, will they provide 100% funding for personnel within a potential earthquake :cne, or tornado region, or hurricane areO What I'm trying to say is, I seriousl'/ doubt FEMA can provide 10C% funding Jithout the floodgates being opened for requests from all over the country for all kinds of hazards.
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Stephen N. Salomon - p2 D.
Finally, you indicate this document presents a program at a cost believed to be efficient, effective, and equitable. Frankly, I didn't see anything that describes how this $147 million is going to be administered over the next 20 years that would make the program efficient and equitable. The disbursement of these funds to the myriad of jurisdictions in t.he United States is going to be difficult, to say the least.
I don't intend the above or the attached comments to be derogatory in any sense.
This is an excellent document representing an awful lot of hard work and you are to be congratulated for your efforts. Your travels throughout the United States undoubtedly brought you into contact with a wide variety of state and local government priorities and competentcy. It should be clear that unless a mechanism is devised to properly administer and coordinate the program it will fail even though $147 million is made available,
"'his point didn't receive the attention it deserves in your report.
If you are available in Bethesda during the ICAC meeting June 18-21, perhaps we can discuss this further.
Sincerely,
. t--
John J. Kearns Assistant Director attachment t
CALIFORNIA CFFICE CF EP sRGENCY SERVICES CCMMENTS REGARDING "BEYCND DEFENSE-IN-CEPTH" NUREG-0553 BY Stephen N. Salomon U. S. Nuclear Regulatory Commission COMMENT Part I Pages I-l & I-2 Refer to cover letter dated June 11, 1979, John J. Kearns to Dr. Stephan N. Salomon.
Part II Pages II-6 The historical costs indicate a great deal of uncertainty about the actual costs of preparing the plans.
I know we did not keep accurate time reports of all staff members involved in this effort, as well as compiling all incidental costs associated with the plan development and distribution.
I'm certain other states faced the same problems we did in trying to answer your questions regarding funding.
Also, on this page you mention " Note that these costs do not reflect State needs necessarily." Are you saying the plans we prepared are not adequate or that they have been written merely to satisfy the requirements of 75/1117 You don't elaborate and I'm not quite sure what you mean.
I!-28 The first paragraph of this page details that few local officials kept good records regarding personnel time devoted to plan devel-opment. The same situation prevailed at the state level and it should be so noted.
II-44 You indicate, "In general, California counties incur costs for local training wrareas in most cases, the states take primary responsibility for training." Your statement makes it sound like we have shunted this responsibility to the county and this just isn't the case.
First of all, by law the county has basic responsibility to handle all dis-en rD '
asters within their boundries. This includes preparation for such O
g disasters; plans, training, exercises, etc.
Secendly, at the state
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level we have a comprehensive training program and all counties includ-(;, es
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ing San Luis Obispo have participated. Granted the counties present C.
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[3; training and conduct exercises without state involvement, but it isn't q
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i them.
This should be clarified.
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jy g1 L-tecause we wcn't or can t ass st Also, the equipment you reference as being purchased by San Luis Obispo County was, I believe, actually paid for by the utility company.
II-46 Wew' tne resource needs submitted to TVA of 3595,000 initial costs ind about 5133,3C0 annual :osts are to say the least, interesting-What do they actually propese to get with this imcunt of money?
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NUREG-0553 - p2 Pac *a II-49 The ccament regirding whether government manpower costs should be viewed as real costs in an interesting one.
I think they become real the minute additional resources or manpower are required above and befond their nc rmal day-to-day operations. Cbviously, highway restoration is a normal function of the Highway Department, but if they have to hire a planner to develop plans to mitigate unique disasters affecting the highways, then this planner is a real cost. As I said its an interest-ing thought.
II-49 & 50 This particular course has reached virtually all of the presently in-volved jurisdictions. However, with the advent of the enlarged plan-ning cones a lot of new jurisdictions will be involved and this course will have to be put "on-the-road" to meet these needs.
II-53 The statement "Some local officials believe that additional costs will be incurred if local plans are reviewed in order to achieve NRC con-
~
currence.
." really scares me.
Does this mean their local plans have been developed without taking concurrence into consideration? Have they ignored 75/111 or what?
Also, I'm not sure why the local plans would cost less than the state plans.
In a way they are much more detailed frem an operaticnal stand-point and would cost as much if not more.
II-56 Again, California vests primary responsiblity in local government and "that's why we had a large number of local attendees at the NRC/ EPA sponsored courses. I should point out that a good many of the locals had a hard time with the mechanics of the course. With this in mind I like the idea of some state representatives attending the course then developing a course to present to county and other local officials.
II-62 I think you are downplaying ARAC on the basis of incomplete meteorolog-ical information when in reality this is not the case.
The criticism comes frem trying to extend information from one location in a state to another location in that state.
Specifically, the ARAC information frcm the OCE facility at Rocky Flats, Colorado was extrapolated for use in the Fort St. Vrain incident and there were minor complications.
when meteorological stations are at sites where ARAC is to be used this shouldn't be a problem.
In fact, we think. ARAC will be one of the best tools available for planning, training, or emergency use.
Also, I somewhat agree with the comment that the " ring system" is too expensive to maintain, but this is based on a CCpA study in Rockvilla,
- 4aryland many years ago.
The present state of the art may be such that this is not new the case.
II-64 The use of NCAA storm alert radios as an alerting mechanism is some-thing we haven't sericusly censidered, but will certainly investigate further. These could be purchased fer those living in remote or in-acceasible areas.
OP7
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NUREG-0553 - p3 P a,e.s
!!-65 I haven't seen anything that says the CD V-138 dosimeter (0-200 mR) is not rugged enough for field use.
We use them in our training program and they are effcetive. Also, I would caution regarding a general statement on the CD V-740 dosimeter (0-20 R) as some of these are prone to leakage and would give false readings.
II-68 The statement at the bottcm of the page is important in that few states have really addressed the problems of fixed facilities other than nuclear power plants. With the Livermore Lab and the Berkeley Labs in California, we face a difficult job and will need lots of help includ-ing funding.
II-69 I don't agree that there are "many points of co=monality" between fixed facility planning and transportation accidents. There may be some, but I doubt there are many.
II-78 The scaling down of the generic EPC's is important for facilities such as Humboldt Bay.
If the 10 and 50 mila planning zenes are based on 1000 MW than there must be a tremendous reduction in planning size for a 63 MW reactor.
Chapter 6 - Funding State Governments and Chapter 7 - Funding Local Governments are an excellent su= mary of the various ways the emergency preparedness programs are funded.
It only serves to point out there is no simple panacea for this problem.
As I pointed out in my cover letter, even if $147 million is made available for the period 1980-2000 without a coordinated method for allocation and accounting the program will fail. This problem needs to be addressed in greater detail.
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