ML19221A585
| ML19221A585 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/21/1978 |
| From: | Collins H NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Cleary P CITIZENS FOR A BETTER ENVIRONMENT |
| Shared Package | |
| ML19221A578 | List: |
| References | |
| SECY-78-450, NUDOCS 7905230248 | |
| Download: ML19221A585 (5) | |
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,,7 NUCLEAR RCGULATORY COMMisslON
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FEI 21E8
.7 Mr. Peter Cleary Citizens for a Better Envirom ent Suite 2610 59 East Van Buren Street Chicago, Illinois 60605
Dear Mr. Cleary:
I appreciate your advising us of a na.;eless State of Illinois Emergency Services and Disaster Agency iepresentative's reactions to the Federal radiological emergency respon e planning effort as outlined in your December 21 letter to me.
First, let me say that your details of our conversation on December 19 are basically as you have outlined theit in the enclosure to your letter.
I have marked up the enclosure with a few corrections, retyped it and am returning it to you.
Regarding the ccmments that wt re expressed by the State of Illinois Emergency Services representative, I would like to respond to each of them in turn:
1.
" Concurrence is worthless.
It encouracos inaction once it has been achieved, and the necole who cive it don't know the ground."
Many States have shot n an interest in receiving 71RC concurrence in their State Radiological Emergency Response Plans.
Presumably they do so because they believe there is some utility for them in the concurrence pt ocess.
We think they view the NRC guidance and the Federal revicw and evaluation process as a means of producing a better plan. i!e accept the idea that good plans can be produced without I:RC concurrence and we hope that concurrence is afforded only to good plans.
As far as the encouragement of " inaction," this is hard for us to understand since ene of the conditions of maintaining NRC concurrence is a successful annual exercise to test the plan, (see Supplement !!o. I to FUREG-75/ill enclosed).
If the State in question should elect not to have periodic exercises, or if their exercises indicate t!et they were either not properly implementing their plan during the exercise, or that their plan was unworkable, fiRC could then withdi aw its c]ncurrence.
79052302ff 165 099 ENCLOSURE 4
Mr. Peter Cleary.
- ' Finally, with regard to the qualifications of the people who' are reviewing the plans, the ieviewers are technical representatives assigned to the relatnd regicns of eight Federal agencies. Generally, in each Federal region three of the reviewers are emergency planning and preparecaess e/perts, four are experts in related technical subjects, and one is an expert in transportation matters. The NRC coordinator for the revieu effort is a health physicist with
.. : experience in reactor health physics in industry and at U.S.
national laboratories, and also has fifteen years experience in
'"' radiological emergency response planning in two national civil-defense regions. They make every effort to acquaint themselves with the State's organizational aspects which is probably uhat is meant by "the ground". We continue to think the concurrenca process is a good one and we have ccnfidence in the competence of the reviewers.
2.
"The trainino is a mix of courses desianed for other thinos, simolv out toaether with little thoucht as to continuity.
We disagree with this Statement. The courses being presented have been developed by a Federal Interagency Training Task Force which is comprised of the various Federal agencies involved in this area.
This task force has tried to design ccurses to satisfy the needs of the States and local governments. The courses were developed by Federal, State and local government
' experts selected by the Training Task Force.
'Three specific courses have been and are being offered. A brief status report and brief curricula for these courses are enclosed.
All training programs are offered at no cost to the State and local governments with tuition, travel and per diem allowance being paid by URC and other Federal agencies. The courses have continuously been upgraded and improved based upon evaluations prepared by bhe students and observers fran the involved Federal agencies. The overall reaction by State and local government personnel attending these courses has been one of enthusiasm and appreciation.
Your point of contact within the Illinois Emergency Services and Disaster Agency is of course entitled to his or her own opinicn, but I can say this, it is a view which is not shared by the majority of other Stac9 agencies.
It is interesting to note that the initial planning course which was conducted in March of 1975 in Battle Creek, liichigan, was attended by two members of the Illinois State Health Department, and two members of the Illinois Civil Defense Organization.
Subsequently, the State of Illinois requested that a total of eight individuals 165 100
Mr. Peter Cleary.
o-attesu subsequent phinning courses. This would indicate that"
.there was some satisfaction '. ith this course on the part of the Statc. Additionally 10 Illinois representatives have attended the Radiological Encrgency Response Operations course and the Radiological Emergercy Responso Coordinators ccurse.
You.=cy wish to contact the attendees at these courses through the State Radiological INalth Officer, Mr. Philip 11. Brunner, Chief
. -(.of the Illinois State Divisicn of Radiological Health who his requested training in the cperations course for fivo additional
'" ~ people frca Illinois.
- 3. "Might it be safer ti stay indoors rather than to evacuate?"
Under some postulatcti caergency situations involving radiological releases frcn nucleer facilities, sheltering as opposed to evacuation certainly might be the opticum protective measure.
- This natter is in part dealt with in the Protective Action Guides Manual of the U.S. Environmental Protection Agency, developed as a part of the Federal guidance to the States. A ccpy of the partially completed manual is enclosed. Additional guidance on Evacuation versus Shelter as a protective censure is being developed by the EPA for inclusten in the manual.
For the current status on these additional guidelines, may I suggest you contact Mr. Floyd Galpin, Director of the EPA's Office of. Radiation Pr grams, telephone (202) 75E-5402.
- 4. "There is no trust between St. ate and utility."
~
We assume that this statement primarily refers to a lack cf tir.cly notification of State and local government organizations by nuclear facility licensees when " events of potential public interest" at a nuclear facility have occurred. This, of course, sometimes raises questions in the minds of State and local governcent people as to whether or not the licensees will inform them promptly if a serious er.argency should arise.
Incidents involving tardy notification of scue State and local governments by sore nuclear utilities have occurred in the past.
Although these events usually have been technically cutside the scope of MRC's statutory or guideline reporting requirements, especially with respect to certain events not involving significant radiological relesses, nevertheless, we reccgnize the advisability for licensea's to report these " events of potential public interest" 165 101
Mr. Peter Cleary ',
promptly to the invcived Stato and local governments. We
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have plans to reemphasize this point to all of our licensees, but the States can also assist in this effort, by sitting down with the licensee representatives, and working out prompt notification schemes.
This is a part of the emergency planning prccess. !!atual trust and confidence must be worked cn, actively, from both sides of the fence, the licensee and the State and its involved local governments..
Finally, as a matter of interest, with regard to radiological incidents in Illinois, primary technical responsibilities lie with the Department of Public licalth. Mr. Philip Erunner, r"!ntioned above, is in charge of these technical responsibilities ia Illinois.
We appreciate ycur giving us the opportunity to cocment on these reactions of the State of Illinois Ercrgency Services and Disaster Agency representative or spokesman who passed them on to you, llhile we may not have pleased everyone in our efforts to assist the States and local govern =cnts in this cceplex area, I challenge anyone to find an area in the energency planning business uhcre so much has been accomplished with such medest resources being available.
Please be assured that f!RC and other involved Federal agencies hc te been, and are, exerting substantial effort in this important arca.
Sincerely, Ddg!nsi signed by brold E. rollina
!!arold E. Collins Assistant Director for Energency Preparedness Office of State Prograas
Enclosures:
As stated cc w/ incoming: !!r. Philip l'. Crunner, Chief Illinois Stcte Division of Radiological Health Mr. E. Eric Jones, Director, State Emergency Scryices and Disaster fgancy 165 102
.~.',r LIST OF NRC AND OTHER FEDERAL AGENCY EMERGENCY PLANNING MATERIALS SENT TO MR. PETER CLEARY OF " CITIZENS FOR A BETTER ENVIRONMENT" 1.
NRC:
" Guide & Checklist for the Development and Evaluation of State and Local Government Radiological Emergency Response Plans in Succort of Fixed Nuclear Facilities" (NUREG-75/111) and Sucolement No.1.
2.
NRC:
Status and description of training Courses available for Radi-ological Emergency Response Planning and Preparedness Personnel (State and Local Government) and brief curricula for these courses.
3.
EPA:
" Manual of Protective Action Guides and Protective Actions for
. Nu '. ear Incidents" (EPA-520/1-75-001) 4.
NRC/ EPA Task Force on Emergency Planning draft report "A Modified Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Succort of Lignt Water Nuclear Power Plants" (NUREG-0396).
165 103 ENCLGSL'RE 4