ML19207B809
| ML19207B809 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/07/1979 |
| From: | White H CALIFORNIA, STATE OF |
| To: | Salomon S NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| RTR-NUREG-0553, RTR-NUREG-553 NUDOCS 7909050307 | |
| Download: ML19207B809 (4) | |
Text
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John J. Drabic, Director
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D r. Stephen N. Salomon State Prog rams Officer Office of State Programa U. S. Nuclear Regulato ry Commission Washington, D. C.
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Dear Dr. Salomon:
This is in response to your request of April 16,19i9 for comments on the draft report entitled "Beyond Defense-in-Depth--Cost and Funding of State and Local Gove rnment Radiological Eme rgency Response Plans and Pre-paredness in Support of Comme rcial Nuclear Power Stations, NURZG-05 53, March 30,1979.
First let. me say I appreciate receiving a copy of your draft report and having the opportunity to make comments. I have enjoyed very much reading the report. It is well written, with numerous inte resting comments, and it deals with the subject of emergency planning and preparedness that you have recognized as not having received adequate attention nor funding in the past.
In the open:ng paragraph of Part I-Executive Summary, page I-1, you define your report, "Beyond Defense-in-Depth" which propcses improve-ments to offsite emergency response pu nning and preparedness, as a contrast to the concept of " Defense-in-Depth" which has emphasized pre-vention of accidental radioactive releases by means of plant design, con-structio n a nd ope ration. To me, the wo rd contrast has ne gative connota-tions: it implies opposition.
I would pref,r to see the relationship pre-sented in more positive terms--as being a strengthened supplement to D e f e ns e -in -Depth. In my judgment, the best protection of public nealth and safety from nuclear power plant risks requires a, proper balancing of both approaches--prevention and planning / preparedness. I think you are to be commended fo r recognizing (prior to the T. M. I. incident) that throughoat the nation there has not been a proper balance between the two; that the planning and preparedness element had not received adequate attention; and for developing a fairly well thought out proposal for strength-ening it.
If it's true that the re ;s something good in everynody ar.d eve r'f-thing, I hope that one of the good things to come out of the T. M. :. exper-ience will be the recognition by the NRC and other federal and state agencies of the serious need to strengthen eme rgency planning and prepa rednes s along the.ines you have proposed.
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3700 BRANCII CENTER ROAD = SACR.01 ENTO. CALIFORNLA 95827 = TELEPHONE (9 to) 360-2111 i SUS 05 C3crj'
Dr. Stephen N. Salomon May 7,1979 The majority of your report contains considerable material on past, current and future funding for nuclear power plant and other emergency planning.
Despite the data gathering problems you encountered, I think you have covered this :omplex subject very well. In Chapter 6 - Future Alternative Fuading Mechanisms (page II-102), I thid your comments under Continuation of Current Hybrid Approach are entirely accurate and appropriate. If any-thing, I would sugge st, or request, that the words: " inadequate, sporadic, uncertain and frustrating" in the first paragraph either be capitalized or unde rlined, and that you a 'd the following: "particularly as it relates to D. C. P. A. fanding. "
In a more serious vein, let me respectfully suggest that you consider expand-ing your remarks in the first paragraph on the top of page II-104. These remarks are applicable tu all emergency planning activities and not just to nuclear power plants. In this regard, let me again state that you should be commended for your recognition of the fact that additional funds are going to have to be injected into federal, state and local emergency planning and preparedness programs if we are to achieve the required balance between protection and preparedness in the interest of public health and safety.
Until this fact is recognized and accepted at all government levels, any discussion regarding various alternative funding mechanisms wi'.1 merely be an exercise in futility.
With respect to the seven proposed program elements outlined on page I-1 of the Executive Summary, my overall reaction is favorable. I think you have fairly well identified the key specific areas that need strengthening, and that you have developed a reasonably well-rounded program to improve those areas. The one program element that I have some questions about is your proposal for $40 million to F.E.M. A. for funding of certain local govern-ment emergency planning agencies at 100%. This is discussed briefly on page II-2 and would apply to all impacted jurisdictions within the proposed new inhalation pathway 10 mile EPZ.
With respect to the $40 million F.E. M. A. element of your proposal, I have both positive and negative feelings. First, my negative feelings. It s eems to me that there is a very consistent opinion by numerous federal, state and local agencies that the faderal effort for civil defense and the hazy off-and-on dual-use concept over the past several years has been--to quote the Library of Congress study--a charade. When considering the limited funding involved: the tremendous amount of red tape and excessive paper work; the long, wavering, uncertain history of federal guidance and direction; and lack of any real progress to date, I find it somewhat difficult to generate aay personal enthusiasm for providing additional funding for local emergency planning and preparednes s tb rough F. E. M. A.
Despite that feeling, it may be bette r to do it that way than to establish a new funding proces s in NRC.
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D r. Stephen N. Salomon May 7,1979 I would also like to suggest an alternative to your proposal of 100% funding of local agencies in the 10 mile EPZ. First, I don't think it would be appro-priate to use funds extracted from the nuclear power industry to fund the local share of the cost for emergency planning and preparedness activities that relate to risks other than nuclear power plants. Secondly, I think the proposed additional funding should cover local planning costs for both pro-posed new E. P. Z. 's.
Although this would include more local agencies than your proposal, I don't titink it would increase your $40 million estimate.
I think you did an excellent job in covering the various funding alternatives.
With reference to your preferred approach, discussed on pages II-115 and 116, it's probably as good as any; and in the aftermath of TMI, it may well be the most viable. One possible alternative might be a combination of increased NRC license fees and state levied energy taxes. This might spread the burden a little more, and the potential of getting additional federal funds might serve as an inducement for more states to levy an energy tax.
For your information, I am also sending you a copy of my report entitled
" Response to Governor's Review Panel Questionnaire on Nuclear Power Plant Emergency Planning. " In this document, I would like to call your attention to my three comments on pages 2 and 3 ef my transmittal letter and to my comments on page 5 regarding the notif..:ation/communicaucus process. This latter item is extremely significant and requires definite improvement.
As I mentioned to you on the telephone, I un very seriously interested in putting together a proposal for a joint federal-state-local project to develop a more adequate emergency response rien for Rancho Seco. This project would include many of the elements of your proposed program. Since the NRC/LLL phase I study on the feasibility of installing ARAC at Rancho Seco will be completed this month, it would not take too much effort to proceed with installation and implementation of a site facility at Rancho Seco. Some automated dose measuring equipment is alr eady in place. In addition, there are 19 offsite locations where dosimetry equipment has been installed. If one of your proposed NRC planning consultants could be made available, we would put together a team of federal, state and local personnel to develop an upgraded emergency plan for Rancho Seco covering both the inhalation pathway and ingestion pathway emergency planning zones. In doing this, we could also evaluate the adequacy of these zones as proposed in NUREG-0396 as compared with planning areas developed on a site-specific basis through use of ARAC.
As for timing, I think it would take about a year to complete the project, and in the process some answers could be developed for many of the still unanswe red questions. When completed, it could pe r' ps serve as a gn E3
Dr. Stephen N. Salomon May 7,1979 national model for a reasonable yet realistic nuclear power plant emergency plan. One very important result could be a better definition and understand-ing of the roles and responsibilities of all the federal, state and local agencies in an emergency response. If this could be accomplished, then perhaps we could have a coordinated team approach with all agencies work-ing toward the same goal at i objective during an actual emergency.
At this stage, I'm not quite sure how to proceed with this. I have discussed the idea with some State, SMUD and County staff and they all think it is worth pursuing. Since the ARAC program at LLL operates primarily under a contract with DCE. I am planning to contact their operations office in San Francisco to discuss it with them. Any thoughts you might have on this will be appreciated.
Steve, let me close by again saying I think you have done an excellent job with this report. You have some good ideas and I hope these comments are of help to you. Good luck in putting your report in final form for the Commis sion. If you have any questions, or if I can be of any further assist-
.ance, please don't hesitate to give me a call.
Best regards,
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H. B. White Emergency Operations Coordinator HBW:mt Attachment cc: Members, Board of Supervisors County Executive John Drsbic Alex Cunningham Dan Richard, Jr.
Don Martin Leonard Rosen 913310
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