ML19249E812
| ML19249E812 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1979 |
| From: | Bradford P, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19249E813 | List: |
| References | |
| REF-10CFR9.7 SECY-79-499, NUDOCS 7910020503 | |
| Download: ML19249E812 (78) | |
Text
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c NUCLE AR REGULATO RY COMMISSION P00R ORIGlK
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I IN THE MATTER OF:
PUBLIC MEETING BRIEFING ON SECY-79-499 - REPORT OF TASK FORCE ON.
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- EMERGENCY PLANNING
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n Place -Washington, D. C.
Date Thursday,13 September 1979 Pages 1 - 77 C) t
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(202)347-3700 rw.chen.:
ACE-FEDERAL REPORTERS,INC.
N OffhisiReponers 444 North Ccpitol Street Washington,0.C 20001 jQ/}
}[9 NATIONWIDE COVERAGE. DAILY
. CR7036 1
?00RBRIBiWl.
DISCLADER This is an unefficial transcript of a meeting of the United States Nuclear Regulatcry Cocmission held on Thursday, 13 Sectombov 1079 in the Commissions's offices at 1717 H 5treet, N. W.,
Washington, D. C.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain
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inaccuracies.
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The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or argument contained herein, except as the Cc= mission may authorize.
1071 100
- R703s 2 l i
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
PUBLIC MEETING 4
5 BRIEFING ON SECY-79-499 - REPORT OF TASK FORCE ON EMERGENCY 6
PLANNING l
7 8
Roc. 1130 9
1717 H Street, N,.
W.
Washington, D.
C.
l 10 Thursday, 13 September 1979 11 The Commission met, pursuant to notice, at 3:35 p.m.
12 BEFORE:
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13 DR. JOSEPH M. EENDRIE, Chairman 14 VICTOR GILINSKY, Commissioner 15 PETER A. BRADFORD, Commissioner 16 JOHN F. AHEARNE, Commissioner 17 PRESENT:
18 Messrs. Carter, Gossick, Bickwit, Chilk, Kenneke, and 19 Engelhardt.
20 21 22 23
........,.,,1 1071 i81 25 i
P00R BENA;>
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PR0 CEED INOS 2
(3:35 p.m.)
3 Cat. tai 6SladEH GILIN5KY:
Ne ere to hear a re port 4
from the task force on emergency planning.
Mr. Carter, I 5
gue ss, is speaking.
o Lee, will you introcuce him?
7 MR. 00 SSICK :
Thank you, Commissioner Gilinsky.
o You recall we were nere on June 28th on a status report by y
the task force that was established in June to undertake the 10 review of our emergency planning activities and to come uc 11 witn recommendations on those things which we f elt necessary to improve the overall ef fort.
13 The task force reported in on August 9th, and that 14 report was sent to you by SECY 79-499 on August 21.
We
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15 triec to put a summary on top of it that might make it a lo li ttle 3asier to digest in a somewhat easier f ashion.
I'm 17 not sure how succe ssf ul that was.
le The way we're going to present this this Iv afternocn, we will ask several people addre ssing each of the 20 major parts of the overall planning effort, to come up and 21 give their part of the report in a very brief f ashion.
It 22 mignt be usef ul if we hanced out to you a tagged copy of the 23 paper here, which will make the enclosures much easier to 24 find.
If you find that useful I am sure you may have made 25 notes on it, but perhaps you can use this just to find what 10/1 162
4 036 07 02 l.tM m te 1
CO '.fi.iI Sb I0I42R AHE ARi1E r Since you raise that, wnen 2
will we 00 ge tting a summary of the public commen ts on the 3
aavanced 4
MR. GOSSICK:
Tom?
5 MR. CARTER:
Mike is reviewing thi s and I think o
Mike's going to ciscuss this.
7 MW. 00 SSICK :
We will be covering that, too, o
shortly.
Y One other matter having to do with the 10 organizational management aspects of this and also mentioned
.I l in the memo t ha t you sent u s, Commissioner Ahearne, we will 12 discuss that toward the end of this briefing.
'Ne have some 13 recommendations on that aspect.
i 14 I would like to touch just briefly on the o ther
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15 questions that you ssked and point out that the various to speakers, as we go through it, will addre ss the questions 17 tha t you have indicated here about what activns have I le o f f ered or have the audit or have the office directors 19 orderec, and those that are pending Commission decision.
20 The major items, of course, I just mentioned.
But there are 21 some other things t why, if or not those things would 22 prejudge the rulemaking.
23 As to cny substantial disagr.eement, to the best of 24 my knowledge, other than perhaps some diff erence of views on 25 the best way to manage this ef f ort, which we can address 107I iB3
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later, there are no minority opinions or cisagreements.
2 In June wnen we were ne re, there was some 3
discu ssion or debate about the moceling ef f ort that was 4
being proposed at that time, wnicn has been set aside, 5
really.
So that is no longer an issue.
o So wi th that, I will ask Mr. Carter to in troduc e 7
the briefing, and then proceed with that.
6 MR. CARfER:
Tha nk yo u,
.'.tr.
Go ss i c k.
Y We have members that represented all tne major 10 offices here today.
In the f ront of the notebook s, we na ve 11 a list -- and I have some extra copies, so maybe you can 12 each work f rom these -- in the order in which they will be 13 discu ssed.
I4 First, I would like to summarize briefly how the
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15 task force-approached this objective and its mission.
We lo had representatives from each office, each major program 17 office within the staff, as members, and in some cases more 0
than one representa tive f rom the of fices.
We created, Iv sep'arate f rom the task force itself, a working group of 20 representatives f rom the offices involved.
21 Tha t working group was headed up by Charlie Sou th, 22 who is also here today and can respond to questions.
They 23 separate themselves f rom the task force while we were 24 working an the Lssues that were being developed for public 25 comment, which the Commission used part of.
And they tried 10/1 184
03o 07 04 o
lnt a te I
and I tnink did a very good job in developing a cescription 2
or tne current emergency planning system and critiquing the 3
current emergency planning system, wnica lec to a group of 4
30 problem areas which are identified very specifically in 5
the Commission paper that came up.
Those issues or problem areas basically were o
7 presented to the ta sk f orce.
The task force discu ssed them e
in detail, lookea very hard at the woraing for tne problem v
areas, trying to really understand, in ter pr e t the wording 10 c hosen oy the working group that supported the task force, il trying to ge t an in-depth understanding of why tnose people 12 chose these problem areas.
13 I think they were massaged very thoroughly.
Then 14 the task force agreed u pon the three problems and chose to
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15 approach the solution of those problems via a series of to action plans, which are represented in the Commission 17 paper.
Each outfit developed their action plan after we had le agreed upon really a cetermination of which office should Iv have a lead role, a support role, whe ther i t was long-term, 20 shor t cerm, f or each of the problem areas.
Then the ac tion 21 plans were develo ped.
22 The way we would like to discu ss the action plans 23 today is go through the major offices as indicated on the 24 agenda and summarize, as Mr. Gossick indicated, the 25 organization ac tion plan, which really comes first in the 10/1 1B5
ntD!DViQ l UL E hk!dk)$
7
.Ca_ o 0 7 00 Li n te 1
Commission pa per.
cie would pref er to disc"ss it last.
2 So witn that, if Brian Grimes will discuss the 3
dnd action plan.
4 CalaI5510dEd AHEARd2 Just to help tnose of us 5
wno mignt have read the paper first, is there going to be any comparison in the way the briefings are conducted 5nd o
7 the way the paper i s laid out?
o MR. CARTER:
We are following the paper in order, basically, except f or the organiza tion --
y 10 COMMISSIONER AHEARNE:
Fine.
But f or example, 11 wnen you go cown the problem, you'll be using tne 12 description of the problems and the solutions as indicated 13 in the pa per?
14 MR. CARTER:
Because of the limited time, we ha ve t
15 not propo s'ed to addre ss each of the problems.
Each office 16 was going to highlight one or two problem areas that they 17 thought were important, then, of course, respond to 18 questions on specific problem areas.
IV COMMISSIONER AHEARNE:
Fine.
20 MR. GRIMES:
With respect to the NRR ef fort -- and 21 I think we have had f airly thorough discussion last week on 22 the team approach, to try to promptly upgrade the state of 23 emergency preparedness at operating reactor f acilities, and 24 I won't go through them and beat that again.
25 We are making progre ss.
The first two site 10/1 iB6
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'tisi ts are next week, followec the f ollowing week by some 2
more site visits on tne first plants being reviewed by the 3
six teams.
And we are oeveloping guidance on action level 4
criteria, which we will provide to the Commission in the 5
next f ew aays for their inf orma cien and possible comment.
o With respect to the problem areas, most of the 7
areas are being addressed in the context of the teams, and e
the one area where we have not yet put significant resources 9
i s o n -- I do n ' t rememoer the numbers.
It is F-2, which is
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10 the last one, wnich is developing crtteria f or joint t
y 11 exercises, to be working with state programs.
12 But our eff orts to date have been getting the 13 teams out, ge tting the emergency re sponse plans r eviewed, as 14 o ppo sed to focusing on the test exercises at thi s point.
15 But all other areas are under way to some degree.
lo 17 18 19 20 21 22 23 24 25 1071 iB7
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COMMISS IONER AHEARNE: It we could go cack to mM 2
proolem area 6.
Could you comment why it wasn't appropriate 3
for the NRR action plan to specifically address that?
4 MR. GRIMES : The problem here that the licensee's 5
responsibility for emergency planning exceeds his direct 6
authority to affect the actions of of f-site o fficials is a r? cognized problem.
But we did not believe that we had the e
S resources, or really. that it was very realistic to expect 9
to change the relationship cetween the federal and state 10 government and private industry in this regard.
11 And we had to recognize tha t as a problem, recognize 12 that our authority is over the licensee, and work through 13 that mechanism.
14 '
COMMISSIONER AHEARNE: When you say it wouldn't be 15 realistic to change i t --
16 MR. GRIMES: Well --
17 COMMISSIONER AHEARNE: Let's put the question whether 18 or not it would be realistic aside just f or a minute.
What 19 Rind of changes would you think would be significant 23 improvement?
21
( At 3:35, Chairman Hendrie ente red the room. )
22 MR. GRIMES: Well, to solve this problem, one would 23 have to give --- to put in eff ect restrictions or penalties 24 on of f-site agencies to in some way compel them to do 25 certain things. I don't think it's realis tic to do that. I 107I 108
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don't have any particular wa' s of approaching it.
.4 MR. GOSSIOK Srian, this is really one of the 2
3 a spec ts of the rule-making that we're in for the legislation 4
that may come about.
You're saying that you can't go ahaad 5
with it and act in advance of whatever is decidad on 5
r ule-ma king, or whatever legislation finally is produced.
MR. GRIMES: That's correct. And further, I don't 4
3 really see a good way to do it, thinking about it myself.
9 MR. GOSSICK: That's one of the questions 10 Commissioner Ahearne of the kind that you ask,.
that 11 would pre-judge, I think, the ru l e-m a k ing --,
12 COMMISSIONER AHEARNE: Well, there could have been 13 a more detailed description of what the proolems were.
14 MR. GOSSICK: Well, this is a very brief summary 15 of that.
16 COMMISSIONER AHEARNE: But this particular sentence 17 wasn' t even considered.
So I imagine that that's as lengthy 13 a summary as there probably is.
19 Go back, then, to page ll(f)(2).
Do you have an 20 estimate of when those joint exercise criteria might be 21 developed?
22 MR. GRIMES: No.
think it's a task that ue have 23 to face in the next two or three months.
Right now we have 24 not put any resources on that.
25 COMMLSSIONER AHEARNE: Once resources are put on it, 1071 i39
336.03.3 11 gsh I
you think then it would be a 2-to 3-month job?
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MR. GRIMES: Yes.
3 CO'4MISSIONER AHEARNE: All right.
4 MR. GOSSICK: Any other questions for Brian before 5
we go on to NMSS action plan?
COMMISSIONER AHEARNE: I imagine r an you get back to the organizational question --
s 3
MR. GOSSICK: Yes, certainly.
9 MR. CARTER: I would like to briefly summarize then 13 and make some points on the NMSS action plan.
11 One of the first impacts of Three Mile Island NMSS 12 I believe was it forced them to take a very hard look at 13 emergency planning within the fuel cycle facilit!9s, and 14 the realization very rapidly that we had not been doing, really 15 the job we.need to do on fuel cycle perspective for 16 emergency planning.
Ie The regulations require emergency plans for Part la 70 licensees, part et Part 70 licensees, fuel processing, 19 f uel facrication
-- you have six conversion plants --
20 and the reprocessing taciliTiW sucIas"NFS, -We st
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21 Valley.
22 There is no specific requirement under Part 3 of 23 by-product material licensees to have emergency plans.
24 Now Squibb, for example, has a voluntary emergency plan, 25 which is a very good plan, we feel.
What we would like to do, 1071 1
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236.03.4 12 gsn I
and what we nave started to do, is to perform detailed J
2 accident analyses for all of our f acilities to determine 3
looking at the criticality, fire, explosion, natural 4
phenomenon, abuse accidents, coupled with the actual location 5
sometimes in urban areas of facilities, what a priority list 6
would be in developing emergency planning for these 7
f acilities.
3 COMMISSIONER GILINSKY: Presumably, the accidents that you analyzed are in the saf ety analysis reports, aren't 10 the/?
11 MR. CARTER: That's correct.
de feel, as indicated 12 in our problem area B-3, which is on page 10 of the NMSS 13 action plan, that the licensee plan really was based on 14 accidents up to and including the most serious design basis 15 accident, which in some cases probaoly, considering Three 15 Mila Island, it is not a serious enough accident to do Ie your planning.
IS COMMISSIONER GIL NSKY: Is that the point then?
19 You're thinking of it in terms of supplementing the discussion 20 of accidents that are being considered?
21 MR. C ARTER: Yes, sir.
Going a step further, 22 looking at the human arror of possibility, nultiple equipment 23 f ailures, whatever we have to look at to see how rerious 24 accident situations could develop in these plants.
And that's 25 what we're thinking about.
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We have some e ffort underway under S-3, as
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summa rized there.
We are just getting started. We're trying 3
to take a look, as we had discussed in the cudget presentations 4
also.
3
( At 3:50, Commissioner Bradford leaves the room.)
5 MR. CARTER: Another problem area identified in the
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NMS3 area which is E-3, which is on page 16, we felt that 8
the task force and the working group felt that the majority 9
of operating f acilities had not been evaluated against the 10 staff's current criteria for emergency planning.
We certainly 11 had to agree with that because the requirements for part 30, 12 by-product f acilities, did not even exist for emergency 13 plans.
14 de wanted to take a hard look at that.
15 Af ter we had gone through these analyses, we want 16 to really come up with pre-conceived framework of a criteria, 14 the s taff guidelines, the regulations to be strengthened if 18 necessary, and the guidance to the licensees, really 19 defining the functions and their responsibilities, of all 23 the participants, the licensors, the licensees, what we 21 would expect from local and state governments surrounding the 22 f acilities, how that would go into or impact the state and 23 local government plans around the f acilities.
24 We recognize the need to expand the regulations 25 in the area of the fuel cycles to cover the other licensees lU/l i^2
336.03.6 14 gsh I
covered now.
We're not sure to what extent we do believe they
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need to ce -- the regs need to be strengthened in Part 10 3
and 50, as they apply specifically to the fuel cycis 4
facilities in lieu of just the reactor language presently 3
the re.
6 We have those efforts underway and we will be 7
coming to the commission in the near future.
We have proposed 3
an action plan to present to the commission proposed by the end of this year, proposed language changes in Part 30 10 and, if necessary, Part 40.
11 That's basically a summary of our approach.
12 COMMISSIONER AHEARNE: You list in Problem F-2 a 13 second review.
14 MR. CARTER: F-2 being evaluation criteria f or 15 drills and. exercises are not defined?
16 COMMISSIONER AHEARNE: Yes.
17 MR. CARTER: Yes.
We would like to reassess the 18 criteria in the procedures for fuel cycle facilities.
19 COMMISS IONER AHEARNE: Now that, you estima te, is 20 a short-term completion term?
21 MR. CARTER: Our priorities now are to do the 22 detailed accident analyses to put a priority ranking, as you 23
.might say, against the facilities..
Take a look at the 24 changes to Part 30 for the by product licenses. As part of 25 that guidance development or thinking of the guidance there 1071 193
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we would have to look at that criteria.
I would estimata 2
it would be the first half of next year.
3 Jim Sniezek can discuss the I&E action plan.
4 5
6 i
S 9
10 11 12 13 s
14 s
g3 16 17 18 19 20 21 22 22 24 25 107i 194
336.09.1 16 gsh MR. SNIEZEK I will highlight the I&E actions
..A 2
that I think are of special interest to the commission.
3 The I&E action plan, the first item is on page 5.
4 One of the problems idantified was that terminal 5
arrangements botween the agancies need approval.
6 They were specifically by IRAP. The meeting with COE and other agencies, members of IRAP,was yesterda e
S And it was their outline, what basically the problems 9
are with IRAP, what can be improved. And what we are 10 pushing for is more and clearer delineation of who is in 11 charge, responsibility, a commitment of resources and not 12 a voluntary assign 'ent of resources.
13 That agency in charge really call on resources of 14 another agency.
15 Noi FEkA rep [esentat[ves were there and they want 16 to fold us under the FEMA concept and give it more 17 statu tory authority.
18 The next meeting is scheduled --- well, by November 19
- ist, we', : to have comments specifically on IRAP, the 20 specifics that we would. like to be changed, in writing. All tra 21 agencies are to come in for comments and thew'ihortly af ter
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22 that, there will be another meeting to discuss where IRAP 23 will go from there.
24 But we believe the basic IRAP f ramework is good, but 25 it needs some hardening as f ar as responsibilities, who's in 1071 195
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charge of specific actions.
J 2
The next item which can be found on pages 7 and 8, 3
it's basically that the instant response program needs 4
revis ion.
That would come out on 3-2.
5 CO MMISS IONER GILINS KY: Let me understand. Would 5
IRAp encompa ss all f ederal e f forts?
i MR. SNIEZEK No.
It would come under the FEMA 3
umbre lla.
But it is really the resources that are available 9
by the agencies that would really respond to a nuclear 10 accident.
11 COMMISSIONER GILINSKY: Nhen you say who is in 12 charge of the accident --
13 MR. SNIEZEX: In other words, if it's an NRC license 14 f acility, who should be calling the shots at the scene? It 15 should probacly be the NRC, as f ar as the coordination of 16 the e ffort.
If it's a DOE facility, DOE would be calling the le shots as to what should be done. If it happened to occur in 18 an agreement state and we were providing support to the 19 agreement state, they would be calling the shots of how they 20 thought the resources should be deployed, what measurements shoul 21 be taken, et cetera, so everyone wouldn't be going helter 22 skelter doing their moni-thing.
There would.be better 23 coordination of the overall monitoring of. the accident.
24 COMMISSIONER GILINSKY: Are you srcaking just of 23 monitoring or of other things, too?
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Are there instructions or recommendations that
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would be given to the licensee in the facility?
3
'4R. SNIEZEX: That would be tied in.
But the details 4
of how they would go, we're not there yet.
5 CHAIRMAN HENDRIE:
But under the overall radiological emergency plan, the federal plan, it would go a lot further I
than just monitoring.
8 MR. SNIEZEK: That's correct.
9 CHAIRMAN HENDRIFt And it would go outside the things 10 that the IRAP plan covers, for instance.
And it would 11 include deployment -- such things as deployment, emergency 12 field kitchens, medical equipment, co ts --
13 MR. SNIEZEK: Right.
That would be outside of 14 IRAP.
15 CHAIRMAN HENDkIEt Part of the f ederal disaster 16 assistance kind of action, And there are some interesting Is questions, then. If we shoyld ever have a Three Mile Island 18 sort of situation, I expect whoever is our senior officer at 19 the site will not want to have to worry about how people 20 are taken care of in terms of provision for people who are 21 evacuated, or something lika that.
22 You will want to be able to call f or an evacuation 23 is one is necessary and trust that there be an appropriate 24 organization out there to take care of it as it moves on out.
25 MR. SNIEZEK IRAP is not ge tting into that type of 107i 177
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discussion.
.4 2
CO'4MISSIONER GILINSKY: Isn't that the responsioility 3
of the state??
4 CHAIRMAN HENDRIE: Yes, I think it is. But thers is 3
substantial federsi aid that turns up.
Remember, there were 6
people from -- what is it, the Federal Disaster Assistance 7
Administration down there in the Governor's -- right outside 8
the Governor's door.
And they deployed a lot of material and 9
people, in fact, in preparation.
And we're waiting for 10 whataver the state. called for.
11 Well, I can see some complicated discussions and 12 trying to sort out who does what, out ocviously, better before 13 than af ter.
14 COMMISSIONER AHEARNE: Clearly, there will be a 15 lot of discussions on that, both in among them or different 16 places.
I would guess that we still have a long way to Is go until we see clearly who is going to be in charge of 18 what.
19 MR. SNIEZEK It's my understanding that FEMA wants 20 to fold IRAP into a small part of the overall umbrella of 21 response.
22 CHAIRMAN HENDRIE: dell, they need to prepare -- they 23 are under a mandate to prepare a national plan and they have 24 got to either replace or refurbish that thing which serves as 25 the overall federal planning document which has the acronym, 10/i 178
236.09.5 20
.RPPNE.
I gue ss I'm unable to help the Reporter with the gsh I
4 2
spelling.
3 COMMISS IONER AHEARNE: I t's F-R-P-P-N-E.
1 CHAIRMAN HENDRIE: Unde r two hours?
And IRAP would 5
be a portion of that.
6 MR. SNIEZEK On pages 7 and 8, there is a discussion 7
about the instant response program needs revisions.
That's 8
a few of the things that are happening right now.
The 9
revised EMP procedures are being outlined for discussions at 10 an E4P meeting the week of September 17.
And the first 11 dedicated phone lines have been insta lled in the operational 12 center going to operating power reactors and selected fuel 13 facili.ies.
14 The second line is scheduled to be installed by the 15 ena o f this, year.
16 On pages 11 and 12 --
14 COMMISSIONER AHEARNE: Jim, could i ask you a IS question?
You mentioned that there is developing rule-making 19 to datermine who pays for the cammunications at the licensee 23 sites.
Is that re ally a major issue?
21 MR. SNIEZEK I don' t believe that is.
I don't 22 think that anything has been started on it.
23 COMMISSIONER AHEARNE: Does it really have to go 24 through rule-making to decide ?
25 MR. SNIEZEK: I'm really not sure if it doe s.
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MR. ENGELHARDT: I am unf amiliar with that particular
.4 2
recommendation.
3 MR. SNIEZEK It's one of the things that's going 4
to OE looked at in the overall sequence, whether it should 5
or not. de really haven't gotten to that area yet.
6 COMMISSIONER AHEARNE: You passed by an item on --
I le t's see, page 6.
And it's, I guess, with reference to 3
problem A-5. It's a report on the NRC role. NRC has not 9
adequately defined its role in emergency response.
10 MR. SNIEZEK What we're looking at are things other than the commission role in emergency response there.
And 12 there was a first meeting of inter-of fice work group to 13 define what should we be doing and they come up with a 14 definition of what we should really do in response to an 15 incident.
16 COMMISSIONER AHEARNE: I gue ss f rom my own point of Il view, I guess I think June, 1980 is a little late.
I would 18 guess that if we don't have a fairly clear picture by the 19 end of the next f ew months in what ought to be our role, we 23 will have a number of people answering for us.
21 I guess I would like to know from the staff what 22 they think, certainly by the end of the year.
June, 1980 is --
23 MR. SNIEZEK I believe by the end of the year we 24 will have a direction we're going as f ar as teams or things 25 of that nature and how we will respond.
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COMMI SSI0 DER AHEARNE: I guess my point was I think
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the NRC, as a body, is going to have to have a clear picture 3'
on what its role is in emergency response.
And that is going 4
to have to ce reached at least in the midst of the 5
rule-making, and certainly by prepara tion of testimony in the 6
early spring.
4 And I just don' t think June, 1980 is going to 3
hack it.
9 MR. GOSSICK: The first step on that problem, 10 Commi ssioner Ahearne, is a little bit involved in this meeting 11 that Jim mentioned ne xt week.
12 I asked Denton and Bill Dircks and Vic Stello to 13 get pulled together based on our experience of Three Mile 14 Island.
Assume another one like that or something of a 15 similar nature happened tomorrow.
What would we do as the 16 EMP7 17 First of all, let's assume that it's the middle of 19 the night and the commissioners are all out of reach, for 19 whatever reason or another, or even if they are -- but at 20 Least we're not ge tting into this other question that we got 21 into of the commission.
22 But what is it that we would do dif ferently in 23 addition to, instead of, in this case from that which we 24 did in Three Mile Island?
25 It's a kind of an interim, if you will, checklist 1071 201 s
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for the EMP as it meets 1.1 the event of another accident.
.4 2
And this will be a first cut at that kind of question.
3 I think it's the kind of things howeve r, that 'will 4
take much further steps.
I thought that it was important tha t 5
we have something like that ready and on hand.
5 COMMISSIONER GILINSKY: Where is the first cut?
7 MR. GOSSICK: That's what we're mee ting on. I think 3
it's dednesday instead of next week, to review a straw man that's being prepared by Vic and his people.
10 COMMISSIONER GILINSKY: And that is something that 11 we will have pretty scon?
12 MR. GOSS ICK: Yes, es soon as we can look at it and 13 decide.
This icoks like it makes some sense.
And we will 14 get it down to you for your comments.
(
15 COMMISSIONER GILINSKY Is this a very complicated 16 q ue s t ion?
I, MR. GOSSICK: I don' t think so.
I told Vic to keep 18 it short and simple because it's the kind of thing that people 19 are going to have to deal with, you know, in the midst of a 20 panic, if that ever happens.
And we don't want it to be a 21 long and complicated thing.
22 But they are examples of things that you know in 23 retrospect we would do it differently.
24 COMMISSIONER AHEARNE: Lee, I think the problem you 25 may find is that, and I think the steps that you are taking 1071 202
336.09.9 24 the point that Jim said he is starting on, gsh I
are :orrect J
2 it is right.
It's just that to then wait until Juns --
3 MR. GOSSICK: I agree with you. We can't survive 4
Just not having anything before June of '80.
Whatever comes 3
out o f this may entail some f urther action that may take 5
longe r.
7 MR. SNIEZEK: The short one was meant to define 3
really what had to ce done.
The refinement comes later.
9 COMMISSIONER AHEARNE: And what I am saying is that 10 I tnink the later ought to be no later than the end of 11 Dec em be r.
12 COMMISSIONER GILINSKY: Or September.
I really don't 13 see it as all that complicated a question, unless I'm really 14 missing some thing here.
15 MR. GOSSICK: We'll get to that this week and find 16 out why it's so complicated or what it is that they anticipate ie in addition to the kind of thing that I was talking about.
18 MR. SNIEZEK On pages 11 and 12, there is a 19 discussion of devoting additional licensing and inspection 20 resources to better implement emergency preparedness efforts 21 by the NRC.
22 As Brian has mentioned, the re are other teams.gpbag out.
23 I&E has representation on each of those teams.
In order to 24 accomplish that, we have deferred our normal routine inspection 25 program in emergency preparedness and we believe that we can 1071 203
)36.09.10 25 gsh I
accomplish this cojective as part of the team reviews for J
2 rigat now.
But as f ar as the recurring reviews of our 3
emergency preparedness efforts, we do not have the resources 4
to implement what we have laid out in the action plan.
5 As you know, we set forth these resources in our 6
'80 supplemental request and it was turned down.
There's 7
a bou t 10 additional people in inspector positions that are 3
necessary to accomplish what we had laid out in that action 9
plan.
10 11 12 l3 14
(
is es o[
16 14 18 19 20 21 22 22 24 25 1071 204
26 336 10 01
'IM an te i
Pages 12 and 13, drobism E-4, to sharpen the 2
incident notification criteria and expediting NRC internal 3
notifications.
From the end of July, criteria was se t to 4
the licensees, power reactor licensees and the selected f uel 5
f acility licensees, the ones that have the hot lines 6
installed, which laid out sharper criteria by which they e
should report problems.
8 COMMISSIONER GILINSKY:
Doe s anyone ever use 9
those?
Because as of a month or so ago, I remember asking 10 and it had never been used or used on one occasion.
11 MR. SNIEZEK The phone?
12 COMMISSIONER GILINSKY:
Yes.
13 MR. SNIEZEK Oh, we get. several phone calls a 14 week coming in on the lines.
If there's a reactor trip, 15 they will normally call on that line, as an example, 16 notif ication.
Il It's normally during the o f f-normal working IS hours.
Normally, during the daytime they make the normal 19 calls to the regional offica.
It it happens at nighttime,
20 the call comes in to the response center.
21 At the same time, in order to prevent delays in 22 notifications during off-normal working hours, all our 23 regional calls are diverted directly to our headquarters 24 opera tions center.
23 COMMISS IONER AHEARNE:
As part of that, are you 1071 2US
27
)36 10 02 MM mte I
providing a set of clear instructions to the people at the 2
other end of the telephone line as to when they ought to use 3
it?
4 MR. SNIEZEK I don't know.
Let me check.
I 5
don't believe they have been written yet, or it's in the 5
plan.
I Joe, is there a clear set of instructions to the 8
licensees on when they should use the hot line?
9 VOICE:
Only in the le tter that we provide to the 10 licensees for the criteria under which to use the phone.
11 Simply all they have to do is pick up.
12 COMMISSIONER AHEARNE:
No, my question wasn't if 13 they knew how to use the phone.
It is when to use it.
The 14 criteria that went out were a little murky.
And my 15 undarstandi,ng was that there was going to be an attempt to 16 at least come out with a clearer set of criteria for the Is licensee.
18 VOICE:
I would say, based on our daily experience 19 with the plants, we're essentially developing a dialogue 20 with telephone operators, and they seem to be reporting 21 many events which are way below any threshold.
22 de haven't come up with any more specific criteria 23 as to when in f act they should pick up the telephone.
We're 24 getting more information than we need.
25 COMMISSIONER AHEARNE:
I guess when I read them 1071 206
23 036 10 03 E'4 mt3 i
my concern really wasn't that you might get more information 2
than you need, but it was possible to be interpreted that 3
you would get less information than you might really want.
4 CO MMISSIONER GILINSKY:
Of course, the main 5
purpose of these things was to make sure that there was a 6
link when either of the parties wanted to use it.
4 COMMISSIONER AHEARNE:
Yes.
In addition, though, 3
that we would want to make sure that they would use it when 9
we would want them to, and my concern was the instructions 10 were still a little murky.
11
'4R. SNI EZEX :
So f ar, we haven't noticed any real 12 proolem in not getting the information reported, that issue 13 being reported to us.
14 Page 16, there is a discussion of need to improve 15 the NRC monitoring capabilities under accident conditions.
15 And right now there is a task force that is working on 17 defining the radiological monitoring improvement 13 capac111 ties that we need, and I expect a draf t report from 19 that task force in November, and a final in December, in 20 time to start orde ring the equipment we think will ce 21 necessary during the next fiscal year.
22 The TLD placement is proceeding, placement of NRC 23 TLDs around the sites.
Letters were sent out to all state 24 health departments soliciting their cooperation.
We have 25 gotten responses, I believe, back from all of them.
All but 1071 207
336 10 04 29 MM mte I
a few states are very anxious to participate.
We expect to 2
have TLDs around five sites in Octooer of this year, and the 3
remainder of the sites by the end of this year.
4 COMMISSIONER AHEARNE:
Do I gather, then, from 5
what you said that some states are not anxious to 6
participate?
s MR. SNIEZEK:
There are a few that are not 3
overwhelmingly enthusiastic with resources involved and 9
things of that nature.
10 No w, the state role here -- we are asking that 11 they would place and collect the TLDs, send them to us for 12 proce ssing, and they would get a copy of all the reports.
13 COMMISSIONER AHEARNE:
Now, for those states that 14 are not enthusiastic, what do we intend to do?
(
15
?fR. SNIEZEK We'll do what we did in some of our 16 other programs, that sometimes we go for a contract with a 17 local high school science teacher, for example.
Or where we 18 have a resident, we may do it ourselves, if we can get a 19 contract.
20 We intend to place the TLDs and collect them.
21 Now, we would like to get the states to do it as a first 22 priority.
Second priority, to contract it outs and third 23 priority, do it ourselves.
But we are going to do it.
24 Those were the highlights that the Commission 25 wanted to hear.
1071 208
30 036 10 05 MM mts 1
CO MMISSIONER AHEARNE:
Just as a question, on page 2
11 of the front summary, assorted problems, under I&E tasks, 3
down under C, you are going to procure operational 4
parameters?
5 MR. SNIEZEK Those are the data links for che 6
operational parameters.
These are explanatory of the basic 7
C.
8 COMMISSIONER AHEARNE:
Yes.
9 MR. CARTER:
Mr. Collins will now discuss the 10 office of State Programs action.
11 MR. COLLINS:
Mr. Chairman and Commissioners, what 12 I thought I would like to do, since we only have a limited 13 amount of time, is to use Enclosure 4, which deals with the i4 office tasks, sor ;ed out by problem, and try to give you at 15 least a quick overview of these individual problem task 16 numbers and how they relate to the general responsiollities 14 in the emergency preparedness area for the Office of State 18 Programs.
19 The first thing you will notice in there is that 20 I tems A-1,- A-2, B-4 a nd E-l in Enclosure 4 all in some 21 manner or another relate to this FRPPNE that the Chairman 22 referred to, the Federal Response Plan for Peacetime Nuclear 23 Emergencies.
24 Dr. Hendrie had a meeting with Mr. Macy the other 25 day concarning the interrelationships between NRC and FEMA, 107l 209
236 10 06 31 MM mte I
and o f course we will be using the preliminary guidance that 2
came out of that meeting between the two heads of the 3
agenc ies to start looking int'o exactly what f orm this 4
Federal Response Plan for Peacetime Nuclear Emergencies may 5
t urn into.
6 FEMA did indicate to us during that meeting that 7
they intend to use the FRPPNE as a starting point and base 8
for the national plan for radiological emergencies.
That's 9
ref erred to in the Hart legislation.
It also relatas 10 somewhat to the pending legislation in S. 562 that requires 11 the NRC to develop an agency plan, and I think our thinking, 12 at least in State Programs -- and I think this is probably 13 shared by some other offices -- is that the development or 14 the lead office role for the development of the agency plan l
15 probably should gravitate towards the Of fice of Inspection 16 and Enforcement.
I COMMISSIONER GILINSKY:
Say that again?
18 MR. COLLINS:
The lead office responsibility in 19 this agency for working on the agency plan called for by the 20 Hart bill should probably gravitate to the Office of 21 Inspection and Enforcement, since they already do now manage 22 the manual chapter which deals with this agency's response, 23 and which would have to be added to and updated and 24 incorporate IRAP and all of these other things that FEMA has 25 got in mind.
1071 210
32 336 10 07 W.* mta i
So, since Inspection and Enforcement already 2
really sits in the leadership role for the existing plan of 3
the agency, such as it is, we feel it's a natural that they 4
continue on with that work.
And since they have already had 5
some initial meetings with the Department of Energy 6
concerning the IRAP and any pending provisions to the IRAP 3
COMMISSIONER AHEARNE:
But to some extent it 9
depends, doesn't it, Lee, on what re solution is reached on 10 any reorganization?
11 MR. GOSS ICK :
Right.
12 MR. COLLINS :
Yes, it would.
But I was talking 13 about the.way thing-are today.
14 The national plan that is referred to, which 15 relates soaswhat to FRPPNE, obviously, if the Hart 16 legislation goes through, will probably be a FEMA 17 responsibility to develop plan for the nation.
IS Now, the FRPPNE is not a plan in itself.
It's a 19 guidance document, as Mr. Macy said the day before 20 yesterday.
It is just that the federal agencies, the 21 30-some odd federal agencies that helped put that thing 22 together, have just not done much with the guidance document 23 to turn it into a federal plan.
24 But it will serve as the base for FEMA getting 25 started on this national plan.
s 1071 2i1
33 36 10 08 MM mte I
C) 4MISSIONER GILINSKY:
Does FEMA expect to 2
develop expertise in accidents --
3 MR. COLLINS:
Radiological?
4 COMMISSIONER GILINSKY:
Yes.
5 MR. COLLINS:
They have some expertise now, 6
Commi ssioner Gilinsky, but it's mainly nuclear war-oriented.
I dhere their existing expertise comes from is the portion of 8
FEMA that was the old Defense Civil Preparedness Agency.
So 9
there is some capability there.
10 COMMISSIONER AHEARNE:
It's a reasonable amount as li f ar as radiological measurement.
12 MR. COLLINS:
With respect to nuclear war.
13 COMMISSIONER AHEARNE:
It's still radiological 14 measurement.
15 MR. COLLINS:
Right.
16 COMMISSIONER AHEARNE:
I don't want to leave the le impression that the nuclear war aspects have anything to do IS with the strategic weapons per se.
I t's the effects that 19 that agency was associated with.
20 MR. COLLINS:
Right.
Of course, many of the 21 instruments that the old Defense Civil Preparedness Agency 22 had, the radiological instruments which have been inherited 23 by FEMA -- and there are millions of these_ instruments out 24 there -- are designed and constructed to respond to 25 weapons-type. fallout.
1071 212
34
)36 10 09 MM mte i
Now, some of those instruments are useful for 2
off-site assessment of accidents which might happen at 3
nucisar power stations, and right now we have a contract 4
witn Idaho National Engineering Laboratory to look at the 5
FEMA instruments to see which of them would be useful in 5
assessing reactor accidents on site.
And we should have an 7
answer out of Idaho perhaps in less than a year.
So those 8
instruments would r7present some additional capability out 2
there.
10 It's just that no one has ever really looked very Il closely at the response of those instruments to the types of 12 radionuclides which can come from a nuclear power station.
13 So that's wny we're doing that now.
The states have astad 14 us to do this.
(
15 QOMMISSIONER GILINSKY:
Some how, this is all 15 getting very complicated. FRPPNE and FEMA and I R A P ---
14 CHAIRMAN HENDRIE:
The first thing you have to do 18 is to learn the acronyms.
19 COMMISSIONER GILINSKY:
Do e s n' t it come down to 23 someone in the Federal Government providing a place to state 21 and other competent authority on whether or not people ought 22 to ge t moved?
I can't imagine that being anyone else but 23 the NRC.
24 COMMISSIONER AHEARNE:
I think it's a little bit 25 broader than that.
1071 213
35
)36 10 10 MM mta i
COMMISSIONER GILINSKY:
The re are othe r aspects,
2 obviously.
3 COMMISS IONER AHEARNE:
A lot of the advanced 4
planning, the coordination of the federal agencies, the 5
state agencies, the private agencies, that in itself is a o
fairly complicated operation.
/
MR. COLLINS:
The whole business of emergency d
preparedness is not just, you know, getting people out of an 9
area.
It encompasses a lot of complex areas, one of the 10 most complex of which is accident assessment, and a great 11 deal of work has to be done in the area of accident 12 assessment.
And that's one of the reasons why we're taking 13 a look at existing instruments that are already out in the 14 hands of state and local people, that might be able to 15 provide them some useful information in the event of an 16 accident, again.
17 But this has all got to be looked at.
The 18 instruments have to be looked at and the response to the 19 instruments has to be examined.
20 COMMISSIONER GILINSKY:
When all is said and done, 21 af ter these assessments, isn't it a question of whether or 22 not persons have to be moved or should be moved, should move 23 out of the way or not?
24 MR. COLLINS:
Well,.you have to make a decision 25 whether you want to move them or shelter them.
Unde r some 1071 2i4
36 336 10 11 MM mte i
situa tions you may not be able to move them, and the 2
protective measure that you might have to opt for is 3
sheltering.
In inclement weather, that's acout all you have 4
got, really.
You wouldn't even be aole to pass out 5
potassium iodide in inclement weather, because you wouldn't 6
be able to get around to the doors if there's six, eight, 7
nine feet of snow.
So they're already sheltered and they'll 9
have to stay there.
If the accident happens with nine feet 9
of snow, some serious considerations --
10 (Laughter.)
11 There are three basic protective measures for 12 provision --
13 CHAIRMAN HENDRIE:
I might be willing to regard 14 that as Class 10.
(
15 (Laughter.)
16 CHAIRMAN HENDRIE:
And just not plan for that.
14 MR. COLLINS:
Right.
la There are three basic protective measures 1) identified for the ten-mile emergency planning zone, whic h 23 went forward to you in a SECY paper, and those are 21 evacuation, sheltering, and thyroid blocking.
That's what 22 it comes out tot or a mixture of those four actions.
23 The ultimate, of course, is evacuation.
24 MR. GOSSICK:
Beyond that, thou gh, suppose there 25 is an evacuation.
The question then is, is it safe to come 1071 2i5
~
336 10 12 37
'4M mte i
back or when is it saf e to come back.
And that's a part 2
tnat, you know, I guess we still say, stay involved in.
Is 3
it going to be our responsioility or whose will it, to make 4
that determination as you see it?
5 Ma. COLLINS:
To re-enter the area?
6 MR. GOSSICK:
Yes.
7 MR. COLLINS:
I'think that will pro bably -- if 3
that ever comes to pass, where people have to leave because 9
of radioactive contamination of an area, I would think that 10 such agencies as this agency, HEW and EPA and FEMA would 11 jointly make such determination as to whether or not they 12 could go back ins HEW from the standpoint of foods, 13 watershed areas, milkshed areast EPA from the standpoint of 14 peoplet HEW fromi the standpoint of people.
13 I, would think that these two agencies would have a lo big role in determining whether or not people could go back li into an area.
18 COMMISSIONER GILINSKY:
But that isn't some thing 19 in which minutes count.
In other words, there is time to 20 do that and improvise if necessary.
If someone gets back a 21 few hours later, it's not the end of the world.
22 MR. COLLINS :
Right.
23 COMMISSIONER GILINSKY:
But it is important to be 24 able to take action on evacuation, if tha t's. called f or, 25 promptly.
And that's something one has to be prepared to 1071 2i6
38 336 10 13 '
MM mts I
do.
2 MR. COLLINS:
Rignt.
3 If I can go on, a couple of other items in 4
Enclo sure 4, C-1 and C-3 specifically relate mainly to 3
guidance, existing guidance and forthcoming guidance.
And 5
it also encompasses not only guidance that this agency has produced, but guidance that other f ederal agencies have 4
3 produced or have not produced, which is needed.
9 de are, in the Office of State Programr 3 at this 10 tima looking at the existing guidance for stat-and local 11 governments and what are the problems with 1".
Although 12 it's fairly comprehensive, one of the things that we know 13 has to.'be done is to delineate in the guidance for 14 emergency plans more clearly the kinds of things that belong 15 to local go,vernment planning and the kinds of things that 16 belong to state government planning and the kinds of things 17 that belong in the plans of both levels of government.
18 de are acquiring some expertise from local 19 governments.
To do this, we already have a temporary 20 employee on board who is a county --- former county employee, 21 with some experience in planning.
And we are getting out an 22 intergovernmental personnel f ellowship, prooably to arrive 23 Sunday of this week, a county civil defense director from 24
'#estchester County near Indian Point, who will come aboard 25 for three months under an intergovernmental f ellowship.
1071 2i7
~
')36 10 14 39 MM mta 1
And the se two Centlemen, to try to help us in 2
giving us some advice as to how to separate out this 3
guidance as it relates to the local governments and state 4
governments.
I think this will be a usef ul exercise and we 5
certainly need the help of these people, because we haven't 6
had any people on the staff with local government experience I
before.
-8 9
10 h 11 S
8 12 co 13 14 15 16 It 18 19 20 21 22 23 24 25 1071 2iB
40 336 12 01 Ml4 mte i
HEd and epa have a suostantial piece of cusine ss 2
to do, and I notice the Chairman sent off a letter the other 3
day to HEW recommending that they complete their work on 4
protective action guides and publish it as federal guidance 5
f or th with.
And I was glad to see tha t le tter go forward.
6 Dr. Hendrie and Mr. Macy also discussed the ousiness on potassium iodida policy.
4 3
CHAIRMAN HENDRIE:
de've go t one i tem, John.
We 9
can put a check ceside that.
10 (Laughter.)
11 MR. COLLINS:
Under B-6(a), I think we can say --
12 so we have some work cut out for us in revising our 13 guidance.
And we also have to look forward that if the Hart 14 legislation or something like it come s down the pike, we
(
!5 have got to, have a weather eye out for it, conve rting the 16 guidance or codifying the guidance into some kind of a le regulatory mode.
18 And of course, we would look into the Office of 19 Standards Development to pick up a big chunk of that 'cind of 20 activity, if it goes that way.
21 One thing I would like to take just a moment on, 22 at le ast for my own part -- and I think I would speal:. for 23 Mr. Grimes wi: 1 NRR -- we would like the Commission to act 24 on our SECY pa..er on the emergency planning zones, if they 25 can, as soon as they can, because we think the 1071 219 4
n 41 036 12 02 MM mte establishment of these emergency planning zones as 2
recommended in that paper is the necessary framework that we 3
all need to put our guidance into better shape.
4 So I would hope that the EPZ business can go 5
forward soon.
6 CHAIRMAN HENDRIE:
Doesn't that preempt a piece of 7
the rulemaking we are trying to carry out, or does it?
8 COMMISS IONER GILINSKY:
If it doesn't, it ought 9
to.
10 COMMISSIONER AHEARNE:
Since I have already said 11 it should, I guess I have already answered that for myself.
12
.MR. COLLINS:
Those of us who spent a lot of time 13 on that SECY paper and the two and a half years on the task 14 force report, we were a little upset when we saw that go
(
15 into the advanced notice of proposed rulemaking as one of 16 the 13 or 14 points.
But nevertheless, it got in there.
17 But we think that at least a policy statement on EpZs might 18 be --
19 COMMISSIONER AHEARNE:
I think we can endorse it.
20 MR. COLLINS:
-- advisable, at least on an interim 21 basis.
22 I would like to make the observation that several 23 states are already running with the emergency planning rene 24 concept and several utL11 ties have indicated to us that they 25 are running with it as well.
91371 220
42 7036 12 03 MM mte 1
COMMISSIONER GILINSKY:
Could we bring that up for 2
consideration?
3 COMMISSIONER AHEARNE:
You can agree with the memo 4
I sent.
5 CHAIRMAN HENDRIE:
Never mind the lobbying over 6
there.
7 Having cited the item, Len, in the notice of 8
rulemaking, so that in principle it is an issue to be 9
discussed, considered in that rulemaking, suppose we wanted 10 to pull it back out and deal with it separately, so that it 11 would either be a given in the rulemaking or --
12 COMMISSI.ONER AHEARNE:
It's one piece, because 13 what the. ulemaking said is, asked for comments on how the 14 recommendations of it ought to be implemented.
There are a 15 number of implementations -- two zones or one major --
16 agreed, a ma jor implementation.
So I think the question 17 really ought to be if you pull that piece of it out.
18 MR. BICKWIT:
You can pull anything out of that 19 rulemaking.
20 CHAIRMAN HENDRIE:
I presume what it would require 21 would be simply Commission action and publication of an 22 amended notice.
23 MR. BICKNIT:
That's right, or you may decide that 24 you don't want to go through the process in order to take a 25 particular action.
In that case, you can take it by 1071 221
036 12 04 43 MM mte 1
policy statement or an immediately effective rule.
2 MR. JAMG0CHIAN:
Excuse me.
I'd like to make a 3
point.
4 My name is Mike Jamgochian, from the Office of 5
Standards Development.
6 The policy statement itself really addresses the 7
EPZ and emergency planning considerations to state and local 8
governments.
The rule change does not address anything to 9
state and local governments.
The rule change is primarily 10 focused to requirements to licensees and applicants.
It's 11 two separate things.
12 CHAIRMAN HENDRIE:
You would regard it as separate 13 enough?.
14 MR. JAMG0CHIAN:
I have, i5 CHAIRMAN HENDRIE:
So I can either agree with the 16 paper or disagree with the paper or something in between, 17 and that --
18
.MR. JAMG0CHIAN:
The policy statement says to the 19 state governments, we think you should plan out to 10 miles 20 and 15 miles.
The proposed rule change that you people have 21 before you now talks to a licensee:
A licensee shall make 22 appropriate arrangements beyond the LPZ out to an area 23 called the EPZ.
24 But again, they are addressed to separate people.
25 CHAIRMAN HENDRIE:
I see.
1071 222
44 336 12 06 MM mte 1
COMMISSIONER AHEARNE:
Vic, just initial it.
2 CHAIRMAN HENDRIE:
You want to show me where to 3
sign it now?
4 (Laughter.)
5 COMMISSIONER AHEARNE:
I' 1.1 send you another copy, 6
Just in case you might have put it somewheres.
7 CHAIRMAN HENDRIE:
Put an X where I should sign.
8 (Laughter.)
9 MR. COLLINS:
One of the other items, F-3, dealt 10 with training and retraining.
As you are aware, gentlemen, 11 we have a f airly substantial training program with state and 12 local governments under way.
One of the criticisms of that 13 training program.was that there were no provisions for 14 retraining of personnel to replace personnel at the state 15 and local government who attritioned out.
16 The turnover rate among state and local 17 governments in some areas is quite high, and one of the 18 reasons we didn't develop any retraining programs was we 19 were just barely able to keep our heads above water training 20 people who had nevar been trained before, and our budgets 21 were limited.
22 Our FY '80 budget is substantially increased over 23 what we had before.
It's about 4800,0GO a year, and we are 24 taking a look at now the retraining needs of the state and 25 local governments.
And I feel we will be able to make 1071 223
336 12 07 4 *.'
MM mte I
progress in that area.
2 Another item in there, A-3, f unding, dealt with, 3
in the main, Dr. Solomon's f unding study which he has --
4 COMMISS IONER AHEARNE:
Before you move to that, 5
while we're still on that particular F-3, could you say a 6
f ew words on what you have in mind on the certification, 7
federal certification of the emergency plannirg?
8 MR. COLLINS.:
Of emergency personnel?
What we had 9
in mind-there, Commissioner Ahearne, was that we would 10 suggest to FEMA, and we are prepared to suggest to FEMA, 11 that they establish the mechanism to certify the personnel 12 by some means.
13 We have the existing training programs in place.
14 The courses are in place.
It's just that we don't have a 15 certification procedure.
What a person gets when he comes 16 out of one of these training programs is a certificate from 17 the contractor or from the NRC, whoever is conducting the 18 program.
19 So we would look to FEMA to establish maybe some 20 kind of a 'ertification mechanism.
In other words, a person 21 could get a certificate if he attended a spe.cial 22 certification qualificati.on.
If he attended all of the 23 emergency planning and preparedness program courses that are 24
-offered, he might get some kind of a rating of A or 25 something like thatt and if he attended just certain ones 1071 224' L:
46 336 12 08 MM mte I
another certification might be given.
2 This might help the states in determining which of 3
their people were qualified to do planning and which were 4
qualified to do response operations and so forth.
We think 5
it's a decent idea and we would look to FEMA to certainly 6
properly assume the role in certification.
7 The funding study, Dr. Solomon's report, 8
NUREG-0553, will be probably out of the print shop any day 9
now.
It was already out in draft form last spring.
And 10 what we intend to do with the funding study is to ensure 11 that it gets up to the Commission with some options and so 12 forth and, more importantly, that it get to FEMA.
Because 13 we think the document will be a very good first cut look at 14 the funding problem at state and local government level for f
15 FEMA.
16 We don't think FEMA has -- we know of no such 17 study that has been made for FEMA or for NRC in the past, 18 and it should be useful to them, in addition to this agency.
19 I would expect that the bulk of any action 20 concerning funding that would be taken as a result of this 21
. study and any forthcoming studies after that would be 22 undertaken by FEMA, because they look like they are going to 23 be the moneybags outfi.t of the Federal Government on 24 emergency planning preparedness.
25 We do have some funds in fiscal '80, S5C3,000, 1071 215
47 036 12 09 MM mte I
if that comes through, where we can put that into some 2
problem site areas for emergency planning around the 3
country.
And we are thinking about possibly the county 4
areas around Indian Point, as a sort of an interim funding 5
measure there.
6 Items D-2 at:18-6 relate to mainly field 7
assistance, our field assistance program and our concurrence 8
program with state and local government plans.
We have 9
expanded our fisid assistance effort.
We have three people 10 from Nuclear Reactor Regulation assigned to the Office of 11 State Programs to help push the review and concurrence 12 function with the states.
13 We have a commitment from all states with 14 operating reactors, with an estimated date when they f eel 15 their plan.would be able to get a concurrence using the 16 existing guidelines.
These dates range all the way from 17 this month all the.way out.o June of 1980 for the last 18 state, which would be Illinois.
19 Illinois has a lot of work to do and they have 20 indicated that they will have a draft plan in to us in 21 December and probably a plan ready for concurrence in June 22 o f.19 80.
23 I think they.are all trying to beat the dates that 24 are set forth in the Hart legislation, and as long as we 25 have an augmentation of personnel in our c.ffice and get the 1071 226
48 336 12 10 MM mte 1
assistance of the other involved offices at the regioral 2
level, the other f ederal agencies, I think we can pull it 3
off and at least get the plans up to the level of meeting 4
today's criterion guidelines.as a first step, and then later 5
implement the concept of emergency planning zones, if the 6
Commission gives us'the green light on that.
7 We wouldn't expect the states to be able to hang 8
the EPZs around each facility immediately.
They would take 9
some time to do that, probably by about January of '81.
10 The response to the Chairman's letters to the
'l l states concerning concurrence has been overwhelmingly good, 12 and we have seen no letters come back from any states 13 indicating that they don't want to cooperate in the existing 14 concurrence program.
15 Finally, the last item, which is B-5, which is 16 research.
A comment was made during the deliberations of 17 the task force that someone ought to take a look at the 18 research that is going on in the emergency preparedness area 19 and the lack of research that's going on.
And our office 20 volunteered to try to prepare a laundry list of all the 21 research activities in emergency preparedness that we know 22 are going on, not only in this agency, but in other f ederal 23 agencies, so that then we and the other federal agencies can 24 look at this and see what needs to be done anc! what's 25 already being done.
1071 227
~036 12.11 49 MM mte 1
And we would hope to have a look-see at what is 2
going on in research inside and outside the agency, and have 3
a list of that activity, and then be able to make some 4
proposals for additional research by the middle of this 5
fall, I would think.
6 I think, Tom, that finishes my presentation.
7 MR. CARTER:
Mike Jamgochian will discuss Office 8
of Standards Development.
9 MR. JAMG0CHIAN:
Gentlemen:
The Office of 10 Standards Development plans to resolve everybody's problens 11 by writing regulations --
12 (Laughter.)
13 MR. JAMG0CHIAN:
-- quick and e asy.
14 COMMISSIONER AHEARNE:
That's emblazened over your 15 doorway, by the way.
16 (Laughter.)
17 MR. JAMG0CHIAN:
Basically, what I wanted to do 18 was, rather than go over specific problem areas laid out in 19 the action plan, go over rules, regulations and regulatory 20 guides that we ha.ve written, are in the process of writing, 21 or what.we plan on doing.
22 One of the problem areas that surfaced was 23 emergency planning for research reactors, and also 24 maintaining emergency plans up to date.
We wrote a rule 25 change.
The Commission approved the proposed rule change.
1071 228
50 036 12 12 MM mte 1
It is to be published in the Federal Register either 2
tomorrow or the beginning of next week.
3 Second, there is a rewrite to Appendix E to 10 CFR 4
50, as well as a change, proposed change, to 5033 and 5054 5
You received the last few pages to the task force report, a 6
first-cut draft of proposed rule changes.
Now, this first 7
cut was simply my own. personal draft as a result of sitting 8
down listening to a number of Commission meetings, your 9
concerns in emergency planning, and sitting down with the 10 various offices, getting their ideas.
11 It was done very quickly, and attached here 12 primarily in the hopes that the Commission could give me an 13
. idea if they have any major problems with the concepts that 14 I have laid out in either the change to 5033, which is
(
15 condition of an application, 5054, conditions of a license, 16 and the rewrite of Appendix E.
17 As of September 1st, I started writing the formal 18 Commission paper which lays out the discussions, the 19 alternatives.
I anticipate getting that through Office 20 review and to the Commission the latter part of September, 21 which, as you probably know, is one week off the schedule 22 that you have directed for that rulemaking.
23 RR. GDSSICKt Mike, that will have the comments 24 included that we have-received or not.?
25 MR. JAMG0CHIAN:
We ll, there's a problem, as with 1071 c29
51 036 12 13 MM mte 1
most things.
We received a great number of comments.
As of 2
today, I believe we received 95 comment letters.
Each 3
letter -- well, approximately maybe five, to ten comments per 4
le tte r.
5 Well, as of the 1st of September, in order to meet 6
your schedule, I had.to start writing the rule, the 7
Commission paper.
We had only received approximately 30 8
comment letters.
I evaluated those comments, reviewed them, 9
and took into consideration all the people's concerns in 10 writing the Commission paper.
11 Well, now, since September 1st and as of today, we 12 received a significant number more.
So you know, I propose 13 to continue forward because of the urgency of the matter and 14 present the paper the latter part of September, with the
(
~ 15 consideration of 30 comment letters.
16 If the Commission doesn't like it that way and 17 wants ine to consider all the comments, you've got to give me 18 more time.
19 COMMLSSI.ONER AHEARNE:
Is there anyone who is 20 looking at the other 65 to see what major points are made 21 throughout that?
22 MR. JAMGOCHIAR That's me.
23 COMMISSIONER AHEARNE:
You're the only person?
24 MR. JAMG0CHIAN:
Yes, sir.
2C Now, the other 65 --- as of today, I anticipate we 1071 230
52 036 12 14 MM mte I
are going to get 300 letters.
This received a a great deal 2
of publicity in the newspapers.
So we are getting quite a 3
bit.
4 So if we want, I can keep reviewing letters.
5 We're going to get them.
6 COMMISSIONER AHEARNE:
I would guess -- let me 7
shift my question over two notches.
8 Lee, is it possible to talk to Bob to see if.it's 9
possible to find someone else to help Mike in reviewing 10 these?
11
.MR. GOSSICK:
We obviously have to look into this 12 to see if there is some way of task forcing a review of 13 comments.
fou know, if the first 30 represent --
14 COMMISSI.ONER AHEARNE:
And having that done, the i
15 task f.orce,not end up being Rike in a dif f erent suit.
16 MR. GOSSICK:
I understand 17 MR. JAMG0CHIAN:
Again, it's as of today we have 18
. received 95.
So you've got to have a cutoff point in order 19 to proceed.with the Commission paper and with rulemaking.
20 COMMISSIONER AHEARNE:
I understand, but there 21
.really has to be more per.sonnel.
22 MR. GOSSICK:
When does the comment period end, 23 Mike?
24 MR. JAMG0CHIAN:
The comment period ended the 1st 25 of September.
1071 231
'036 12 15 53 MM mte 1
MR. 00SSICK:
So these are late comments, in 2
effect.
3 MR. JAMG0CHIAN:
But that's usual.
4 MR. GOSS ICK:
That's normal.
5 COMMISSIONER AHEARNE:
So you really need someone 6
else to help review those.
7 MR. JAMG0CHIAN:
What I anticipated doing was, 8
yes, continue reviewing them, and if there's any major 9
problem, then surf ace that when the Commission reviews the 10 p.roposed rule changes.
But again, this is only proposed 11 rule changest it's not effective rule changer
_ 12 What I had anticipated doing was, prior to writing 13
.the Commission paper on the final rule changes, is have a
(
thorough detailed analysis of all comments.
14 15
.To address one of the questions I believe you had 16 relative to the EPA-NRC task force, the comments that I 17 reviewed, the 30, I did a fairly thorough evaluation of them 18 and none of them, as of September 1st, had any problems with 19 the EPA-NRC. task force report.
To be fair, many of them had 20 never heard of it.
21
-(Laughte r..)
22 I have sent out 10 or.12 EPA-NRC task force 23 reports to concerned citizens.
24 But to try to look at.the questions that were sent 25 out in the-Federal Register notice, you know, it's a lot of 1071 232
54 036 12 16 MM mte 1
concern to people at home that are simply saying, I live
/
2 three miles or five miles from the plant and I'm worried.
3 They are truly concerned.
4 Well, that EPA-NRC task force recommendation in 5
essence takes into account, because we're saying, all right, 6
we have to have emergency plans out to ten miles.
So may of 7
them are concerned that they never heard of an emergency 8
plan and that they live four miles, five miles, down the 9
road from a nuclear power plant.
10 So when I said that, they would like the concept 11 of emergency planning out to that distance.
Many of the 12 states -- well, not many.
A few of the states, in glancing 13
'through the other 90, the states had said that they were 14 concerned as to NR.C's role during emergency.
Is Harold 15 Denton going to come down and take.over everything as soon 16 as an emergency happens, that kind of a thing.
17 It was sincere concern.
You know, why should we 18 plan if NRC is going to take over the ballgame.
So that was 19 a concern.
20 CHAIRMAN HENDRIE2 We only book Harold one 21 engagement at a time.
22
.MR. JAMG0CHIAN And as of September 1st,.we had 23 no comments from the utilities.
24 Relative to the. Appendix E change, I would like to 25 simply go.over.the major changes.
Basi-cally, we have 1071 233
55
'036 12 17 MM mte 1
required that implementing procedures be submitted as part 2
of the FSAR for staff review and approval.
These are major 3
changes.
4 Number two, we have extended emergency planning 5
consideration of licensees cut to an EPZ1 and, number three, 6
requiring as a condition of an application and license that 7
state and local government emergency response plans be 8
submitted and concurred in by NRC.
9 Those are the three big changes.
Tne other 10 changes are, if you would, sharpening, clarifying, Appendix 11 E, being more specific where it has been perceived that it
. 12 hasn't been specific enough.
Basically, that's the change 13 in Appendix E.
14 ince Appendix E is changed and approved in final 15 rule form,.I anticipate on proceeding with revising 16 Regulatory Guide 1.101 as well as Regulatory Guide 2.6, 17 which is emergency planning for research reactors, and 18 Regulatory Guide 3.42, I believe it is, emergency planning 19 for Par.t 7 people.
20 COMMISSIONER AHEARNE:
In your perspective, what 21 ought to be the. sequence of those changes with respect to 22 the rulemaking?
23 MR. JAMGGCHIAN:
What do you mean oy the sequence?
24 COMMISSIONER AHEARNE:
Should the emergency 25 planning rulemaking be finished first before you make those 107\\
254
56 036 12 01 MM mte 1
MR. JAMG0CHIAN:
Two regulatory guides?
Fiell, the 2
basis for the regulatory guide is a rule.
The foundation is 3
the rule.
4 COMMISSIONER AHEARNE:
Yes, so that we really 5
ought to defer real consideration of those until after we 6
finalize the rulemaking.
7 MR. JAMG0CHIAN:
Most definitely.
I thought I 8
brought that out.
Once Appendix E is written in its final 9
form, then I'll proceed with rewriting regulatory guides.
10 Basically, that's it.
Any problems?
11 (Laughte r. )
12 COMMISSIONER AHEARNE:
The largest problem is you 13 don't have enough people to hel:n you.'
14 MR. KENNEKE Let me ask you a question following 15 Commissioncr Ahearne.
If you say you must have a rule 16 before you can get the guides, nevertheless one of the 17 elements of the rule is that the licensee submit a state 18 plan, which in turn mus' incorporate local plans.
19 What are we doing to provide the guidance, in 20 upgrading the guidance to the locals in particular, so that 21 whatever the licensee submits will be acceptabla and meet 22 whatever c.~.iteria we have.?
23 We need to go forward on both elements together.
24 MR. JAMGGCRIAN:
Nell, the crite-ia for accepting 25 or concurring in a state plan has.already been set.out 1071 235
57 036 12 02 MM mte 1
by State Programs in NUREG-75111.
2 COMMISSIONER AHEARNE:
But it's a little weak, as 3
has been pointed out, on where the state is and where the 4
local is.
I think A1 --
5 MR. JAMGCCHIAN:
Basically, we're going on what's 6
on the books now.
As a cond. tion of application and as a 7
condition of license, a concurred-in state plan will be 8
required, according to the regulations.
9 MR. KENNEKE:
No change from present criteria as 10 reflected in 7511?
11 MR. JAMG0CHIAN:
Correct.
The action as it stands 12 today.
13 COMMISSIONER AHEARNE:
That, of course, is one of 14 the things that the rulemaking is addressing?
15
,MR. JAMGOCHIANr Concurrence.
16 MR. KENNEKE:
.It may not be.
17 COMMISSIONER AHEARNE:
Also, what ought to be in 18 the Office of Local Planners.
19 MR. JAMG0CHIAN:
.Not in this rule change.
The 20 Hart bill says that the criteria for concurrence will then 21 be put in our regulations.
22 COMMISSIONER AHEARNE:
What I am saying is at 23 least a notice for rulemaking had addressed one of the 24 issues of what.are the cr_iteria.
25 MR. JAMG0CHIAN:
Oh, yes, the advanced notice.
1071 236
58 036 12 03 MM mte i
That's true.
2 COMMISSIONER AHEARNE:
So at least I trust, since 3
that was in the advanced notice, it to some extent will be 4
addressed in the rulemaking.
5
.MR. JAMG0CHIAN:
Not this particular rulemaking:
6 another rulemaking at a later date.
The advanced notice 7
went out with a lot of general questions:
What do you 8
people think about emergency planning?
You know, very 9
general questions.
And we're getting very general -- in 10 many of them,' very ge7eral comments.
11 COMMISSIONE:R_ AHEARNE:
Yes.
I think some of those 12 general questions were under the assumption that the rule 13 would answer those general questions specifically.
14 MR. KENNEKE Mike has given the draft rule, and 15 it goas only to the requirement that a licensee submit a 16 plan.
It does not specify the criterion as part of the 17 guidance I assume you are seeking --
19 MR. GOSSICK:
That's intended to be a separate 19 rulemaking with regard to the guidance to the state.
20 MR. JAMGOCHIAN That's correct.
We cannot put in 21 our rules right. now regulations to states.
We have no right 22 to regulate states.
.aur regulations, as I understand them, 23
.are primarily to licensees and applicants.
24 COMMISSIONER AHEARNE:
Certainly.
We can 25 certainly say; can't we, that, here, licensee, we are 1071 137
59 036 12 04 MM mte I
telling you you will not get a license unless the state plan 2
has X, Y, Z in it?
3 MR. JAMG0CHIAN:
Yes.
4 COMMISSIONER AHEARNds Can't we do that?
5 MR. BICKNIT:
I assume that we are proposing --
6 you are contemplating a proposed rule which would say that.
7 MR. KENNLKE:
That is not in Mike's proposal.
8 MK, BI.CKWIT:
What is in your proposal, as I 9
understood it, was a requirement of a concurred-in state 10 plan as a condition to a. license.
11 MR. JAMG0CHIAN:
Yes, sir.
_ 12 MR. BICKNIT:
If you can require that as a 13 condition to.a. license, you can require that it say certain 14 things.
15 MR. JAMG0CHIAN Okay.
16 MR. BICKWIT As I read the advanced notice for 17 proposed rulemaking, we were going to confront that issue in 18 the rulemakinge just what crItaria should we provide to the 19 states and localities.
20 3
21
,, d /
I 22 23 24 25 1071 238
60 Cr7036 i
T14 mm1 1
MR. GOSSICK:
The point Mike made is that guidance
- 4ET *ZER 2
such as this is what you reed to start putting together the 3
final proposed rule.
4 MR. JAMGOCHIAN:
That's true.
5 But to lay out more specifically the acceptance 6
criteria for state and local government concurrence in our regulations now is much broader in scope than I had anticipated.I 7
8 Again the rulemaking proceedings that you had directed 9
originally is under very stiff scheduling.
10 COMMISSIONER AHEARNE:
Right.
11 MR. JAMGOCHIAN:
If the scope has to be expanded --
12 MR. BICKWIT:
Just one relevant factor.
In the 13 Hart Bill, within six months of enactment, the Commission 14 would be required if the bill passes in its present form, to 15 have promulgated a stepup in the criteria for states and 16 localities.
It said, in effect, if that schedule is to be met, 17 then this would appear to be the appropriate rulemaking to 18 deal with
- hat issue.
19 MR. KENNEKE:
If I may follow this up, as I 20 understand both NRR and State programs as they look at both 21 sides of their action plans, one with state plans and one with 22 licensee plans, are looking at local plans under the present 23 criteria?
24 MR. CARTER:
I think they should speak to that.
I Am FWmI Roomn. ix.
25 would assume they are.
1071 239 i
61 j
MR. GRIMES:
Yes. The test teams for NRR are looking, 2
at the adequacy of the plans around the facility which includes 3
the stas and local plans, and would have some draft or interim criteria that we are using, aid we will have some action level 4
l criteria als o for interim use which we will be getting experienc 5
with over the coming months and will undoubtedly we will l
6 7
change and develop as we use it.
So the answer is NRR will be looking at that.
I 8
am not sure the extent to which State Programs in their 9
10 current exercise is looking at focusing on locals because 11 they are using the same criteria as of July 16, specified in the Hart Bill for their concurrence exercise.
12 13 But there is some look at local plans through the team effort.
- 4 15 MR. COLLINS
Collins, State Programs.
16 We are looking at local government plans in the j7 same light that we have paid attention to them in the past.
In other words, we ere looking for them as a part 18 19 of the state plan.
Right now we are in a mode as I explained, of trying to be a little more definitive with respect to what 20 we expect to see in the local plan, vis a vis our existing 21 guidance and what we expect to see in the state plan and 22 what should be in both.
23 l
24 Naturally, since we haven't paid a great deal of Ace FederW Reporters, Inc.
25 attention to separating the guidance elements at st1te l
l 1071 2,0
62 mm3 1
level or local government level before simply because we 2
didn't have the staff to do it, and to look at local plans, we 3
are in kind of a mode right now what should be in local l'
4 plans.
But we intend to work with Nuclear Rea ctor Regulation.
5 And I think between the two offices we can quickly I
6 straighten this out.
7 MR. GRIMES:
With respect to rulemaking I think 8
it is a question of how much detail you want to put in the 9
rule.
10 You can take these draft doctaents, guidance II documents and put them out as the proposed rules, I suppose.
12 But I think that is a good deal too detailed, given our current 13 state of development of the documents.
14 COMMISSIGNER AHEARNE:
Mike, am I correct that you 15 are the only person working on this advanced rulemaking?
16 MR..JAMGOCHIAN:
Yes, sir, in the Office of Standards!
17 Development.
18 COMMISSIONER AHFARNE: But you don't have other 19 people working with you?
20 MR. JAMGOCHIAN:
No, I'm the bottom.
21 (Laughter) 2-COMMISSIONER AHEARNE:
Or the top.
23 (Laughter) 24 For example you don't have an ELD lawyer full-time Ace Federst Rooorters, Inc.
25 working with you?
1071 2,6
63 l
- nm4 1
MR. JAMGOCHIAN:
No.
2 See, af ter the task force had this task force 3
report submitted, we wanted a rule change to attach to it.
4 I did have ELD input into that rule, into this package that 5
you got, as well as NRR, State Programs and I&E.
l 6
COMMISSIONER AHEARNE:
I recognize that.
l 7
I'm really trying to make sure that I understand --
l 8
and I think I do.
Thank you.
9 MR. GOSSICK:
he is the Lone Ranger.
I 10 (Laughter.)
11 CHAIRMAN HENDRIE: Very good.
12 MR. JAMGOCHIAN: Thank you.
13 MR. CARTER:
We do have one other section to 14 discuss.
15 CHAIRMAN HENDRIE: Can we move briskly to it.
16 MR. CARTER: Yes, sir.
17 Mr..
Durst?
18 MR. DURST:
Gentlemen, it is my purpose to briefly 19 review that portion of the task force r view called the NRC 20 Actions Plans, which is the first of the action plans attached 21 to : Appendix 3 tolthe report 3s enclosure 3.
22 I might say I got this job of having the perspective 23 of the EDO or the NRC with Mr. Carter, when working with the 24 task force when it was first put together, assigned me I
Ace-Federal Reporters, Inc.
25 some representative research as the least involved person both 10./1 mc42
i I
64 mm5 I
in past and the future of the subject.
2 The first task of different tasks he gave me, was 3
that of critiquing the present status of NRC defining implemen-4 tation and everything associated with emergency response.
5 He has already cited the results of this effort, l
6 which were achieved primarily by the working group under the 7
direction of Mr. South and some slight help from me.
These are 8
contained in the report.
9 I think I wouliagree with Tom that the work they 10 did deserve high compliments.
I think it is a decisive II analysis of what is going on and whatever the NRC may do to 12 take future actions, they should surely start with the address 13 of the problems identified in this plan.
I4 Secondly, as the task force was coming to its 15 reporting time, Mr. Carter asked me then to take the action 16 plans submitted by the action offices that was required, and I7 attempt to summarize those more on a linear basis than an 18 analytic basis and to make some limited analysis of the value 19 which they had as a basis for future action by the NRC in 20 achieving its overall policy.
2I The results of this are contained in the action 22 plan, specifically pages 3 through 5, summarize what has 23 existed in the past, and include the fact that Mr. Jamgochian 24 has been the Lone Ranger for a long time in the Office of j
Ace-Federal Reporters, Inc.
25 l
S tandards.
10./1 243
l I
~
65 l
mm6 1
And posits the estimates of each individual action
(
2 office in what 'it views will be its requirements b meet their 3
responsibilities.
4 The rough figures are that summation of these 5
action plans connotes a threefold increase of resources or 6
something on the order of 16, to add an additional 44.
7 The action plans were less precise in dollars.
8 Some dollar figures were cited and a deduction can.be that 9
dollars might be roughly not dissimilar from the figures that 10 were cited for manpower, although were not dealt with in that II detail.
12 Having analyzed the plans, some preliminary results 13 were made.
These results begin on page 6, and they state I I4 think in a pretty agreed way that the short-run recommendation 15 of the task force, parts of the schedule which is at 16 Table 2, provides fairly reasonable compliance wiht the wishes 17 which.the Commissioners exhibited, and the timetable that you 18 wish to follow.
19 It is a possible schedule but it is not an easy 20 schedule as Mr. Jamgochian has just said.
But if we desire 21 to meet that schedule, or if the Commissioners or staff do, 22 it is indeed possible to squeeze and come very close to meeting 23 it.
I 24 In the long range the product of the task force l
AwFWwel Reorun, inc.
25 i
q f
10/,i cs4
i 66 j
i mm7 1
is less defined.
t 2
I think on page 8 which summarizes the recommenda-3 tions of the task force for the long range are really essentiall l
4 three points:
5 The first, that the task force should be dissolved, 6
which -- the reasons for which are stated quite extensively.
7 Secondly, that if in response to the requirements 8
which the new rules impose upon the public we will require 9
again an.
by the NRC over an extended period 10 of time.
II Explicitly, the action plans did not address one 12 of the elements which was contained in many of the topics 13 put forth by the working group, and that was that there is 14 and has been a lack of coordination among some of the policies 15 which NRC has put together, and perhaps in some cases even 16 confusion.
17 Stated previously, a nd I just cite it, a lot 18 of this does come because resources devoted to this thing 19 quite limited it to that.
20 But at the same time it was the feeling of the 21 task force which does agree with the recommendations on page 22 8, that if the NRC is to increase its effort in this field, 23 that some more positive means of coordination will be required.
24 And a specific recommendation, a consideration of the Am Fewal Recemn, te, 25 technical assistant to the EDO to assist the EDO in coordinating 107i
5
l 67 over the long run, a concerted effort by all offices, seems j
2l reasonable.
l 3
I have nothing else.
If you have any questions --
COMMISSIONER AHEARNE:
Perhaps you might address --
4 l
MR. GOSSICK:
Well, I think clearly what we have 5
i l
been doing here this afternoon points to the need for some 6
t better management approach toward s integrating all of the 7
various items and actions that are going on in the various 8
9 parts of the organization.
10 I guess one can start with one solution of trying to 11 pull it all out and put it together.
I frankly don't think that that's a workable solution.
12 13 COMMISSIONER AHEARNE:
Why not?
ja MR. GOSSICK:
I just believe too many of these 15 things are so intertwined with the I&E function,with the NRR 16 function, that if you take it away and have a central office 17 in charge of it, then when you come to implement an action, 18 an emergency response of some sort, you are going to have 19 another problem of having the involved offices aware and current 20 up to date on what has been done with regard to planning.
21 Maybe you say, okay, let this office be.in charge of the event.
I don' t really think that that is too good.
It 22 23 has problems.
It also has some attractions in other respects.
24 COMMISSIONER GILINSKY: Wait a minute.
Acs Federal Reporters, Inc.
The distinction of b'ing in charge of an event and 25 10/1 296
i I
I 68 l
""9 making sure that the various utilities and other localities 1
2 and so on have adequate plans and check them out beforehand, l
i 3
that is really what this group is doing.
State Programs isn't ;
4 in charge of any event.
The emergency people review the 5
conformance to various Reg Guides and NRR are in charge of 6
NRC's response to an accident.
They deal with our reviews 7
of utilities' plans.
8 And there has been a gap, it seems to me, pretty 9
clearly between on the one hand our review of utility plans 10 in NRR, and review of state plans in State Programs.
11,
And as far as I'm concerned, I think these two 12 groups ought to be brought together.
I'm not sure just where 13 I would put them, and --
14 MR.GOSSICK:
I think that's a problem. And you 15 go further and also take that part of the emergency planning 16 function that I&E is also wrestling with --
17 COMMISSIONER GILINSKY: I think I might put them in 18 I&E.
I'll tell you why:
19 Just as I think there is a problem in having a 20 health and safety function in basically a liaison office which 21 irbasically what State Programs is, I also think there is a 22 certain conflict in having an emergency planning off'.ce in 23 NRR.
And one of the reasons we haven't had good emergency 24 planning is that, I think to do too much on that side seems Aa Federal Reporters, Inc.
25 to suggest we haven't done quite enough in reviewing the plan. i 10/1 247
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I responsibilities separated.
In other words, those who review 2
the plan shouldn't be assuming that their review wasn't l
4 adequate, there was an accident, the emergency planning will 5
take care of it..
6 In just the same way the emergency planners shouldn't 7
be assuming too much about how effectively the reviews have been 8
conducted and be too confident about avoiding any sorts of 9
accidents.
10 So it may be that one wants to take it out of NRR, 11 too.
12 in any case, I do think it is important that these 3
activities be brought together, particularly if we are 14 talking a bout requiring state plans as a condition -- and 15 local plans as a condition of licenses.
16 MR GOSSICK:
I certainly don't disagree with the II need for tighter integration and the possibility of moving 18 it all to one place or another, I think is sometning that would 19 need to be studied certainly more carefully than we have delved 0
into that.
21 I think as an interim measure, at least an interim 22 that I think as opposed to the creation of a technicali
- measure, 23 assistant. or something to serve as the central point for 24 coordinating all this effort, making sure that things don't ice Federal Reporters, Inc.
25 get dropped in the cracks, that problems are elevated up to 10i\\
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2 at least for the moment, assigning this overall role to the l
3 deputy, currently acting deputy EDO.
I may have to give him 4
a legman to help stay current with the program, because this 1
l 5
is something that I think is almost a fulltime task for 6
somebody cutting across the parts of the Staff where this l
7 activity is currently going on and trying to track reporting 8
progress.
9 But the overall structure, you know, that is of l
10 more extensive reorgani::ation and taking all, or at least II parts of the current effort and putting it in one place is 12 something that we frankly have not studied the ramifications 13 og, 14 COMMISSIONER AHEARNE:
Well, I asked you last 15 week, to be prepared today to at least address that.
_That 16 was my Item No. 4.
17 MR. GOSSICK: Yes.
18 I'm not prepared to tell you that we have studied l9 and come up with alternatives, options and pros and cons of 20 various organizational fixes.
21 COMMISSIONER AHEARNE:
I asked you for specific 22 things.
I1 asked you to describe the formation of a separate 23 staff office, whose.
role would be to develop, coordinate 24 and insure the implementation of emergency planning action l
Aco-Federal Reporters, Inc.
25 and give me an estimate of what functions it might take over.
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I think your answer is that you are not ready to I
I 2
address that?
3 MR. GOSSICK: Only to the extent that as far as 4
coordinating the effort, assuming that you are leaving the l
l 5
functions where they are as opposed to trying to consolidate 6
them.
7 COMMISSIONER AHEARNE:
I think the request is, is 8
a consolidaticn necessary.
Certainly that is what I intended 9
to write.
I l
10 And I say which functions it would, take over, it l
11 llis a single office that would develop and coordinate.
I 12 MR. GOSSICK:
I think that is the subject of a study 13 that has to be very carefully done, and there frankly wasn't.
14 time to do it.
15 If it is your desire that we undertake such a study, 16 fine, we will do that.
17 I think even if we do though, for the time being I 18 wouB~ propose my going ahead with assigning the current 19 continuing responsibility of integrating and coordinating 20 this effort as I have indicated.
21 COMMISSIONER AHEARNE:
I guess I thought back when 22 this emergency task force was being started, I can remember 23 one of the specific questions you asked to have addressed --
24 COMMISSIONER GILINSKY:
That's what I thought.
Aa4Musl Rgomn. Inc, l
25 COMMISSIONER AHEARNE:
-- was to have it all pulled ;
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together in a single office.
2 MR. GOSSICK:
I don't believe that was in the guidanc 3!
that came through from Mr. Chilk, and I don't recall it being i
4 put in that many words.
l 5
Do you, Tom?
6 MR. CARTER:
No.
7 CEAIRMAN HENDRIE:
I don't recall it in those 8
terms.
I may be wrong.
9 MR. GOSSICK:
I think we reviewed that charter with 10 you and our understanding of that charter, on June 28th --
11 we 1, if we missed it, I'm sorry.
12 COMMISSIONER GILINSKY: Well, I'd like to see it 13 brought together in one place.
14 CHAIRMAN EENDRIE:
What activities do you have 15 in ndnd?
16 Everything connected with emergency planning?
17 COMMISSIONER GILINSKY: Well, I would certainly put 18 together the activities that are now presently in NRR with 19 thor e in State Programs.
20 CHAIRMAN HENDRIE: So that NRR would not have any-21 thing to do with emergency planning?
22 COMMISSIONER GILINSKY:
I didn't say where I would 23 put them.
We might put them in NRR.
But I see a problem 24 about doing that.
Ace Federet Reporters, Inc.
25 But I do think it is better to have them together in, 1071 251
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NRR than separate the way they are now.
2 MR. GOSSICK:
I think I can perceive some real l
3 management problems with that.
Again it is going to be 4
something that is going to take some study and careful looking 5
at the implications of this, resource impact, interactions, 6
understanding with staff by this office, wherever it is, to 7
do things like it currently is doing, field surveys _and;_all that 8
sort of thing, unless you provide a directive for that.
9 I guess another, just a point to mention, in 10 creating a separate additional office is, I get a little 11 concerned about, if a special. topic comes :up, we keep adding 12 another special office of some kind.
It Juggests that either 1
13 something is wrong with our basic structure -- maybe there is.
14 And also it adds a span of control, an additional cormunication 15 problem.
16 You may have cure problem. You have now 17 created another set of proi
. to deal with.
Interaction i
18 communications, and so forth.
19 COMMISSIONER AHEARNE: That's one of the disadvantages 20 Yes.
21 CHAIRMAN HENDRIE:
Especially considering that we 22 start with a set of statutory offices which anchor major 23 portions of the organization in a certain way, which we are 24 not free to redeal.
Aa-FWmI Rmomn Inc 25 I am very leery of establishing -- every time a i
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1 problem comes up, establishing an office.
If Problem A comes 2
up, good, we will now have the Office of A.
Problem B,
- good, f
3l we will have the Office of B.
4 It is a random organizational approach which doesn'tj S
take account of the overall responsibilities for distribution l
l 6
of resources that are necessary to priorities. It is just 7
simply a reactive response. Every time we get a problem that 8
is causing trouble, good, we need an office for that.
And 9
they do their thing.
10 Now we would have some problems with that.
11 That doesn't necessarily mean that some reconfiguring 12 of places, arrangements by which we deal with these things i
13 aren't, appropriate and shouldn't be considered.
But I think 14 we ought to come very carefully and with careful thought of 15 a reorganization for this purpose.
16 In the meantime I would suggest to you that whatever 17 we may eventra' Ly decide about this, that the Staff has to 18 keep collected on all of these things going en tomorrow, the 19 next day and so on.
And what the Executive Director is saying 20 is that he proposes to establish responsibility to the Acting 21 Deputy and bring into his office a fulltime professional 22 who would, on the Deputy's behalf, be the cognizant engineer 23 for emergency planning throughout the agency just to keep 24 track of it in your office.
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25 As an interim measure, that seems to me reasonable.
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It looks like these things are developing enough 2
different elements in different places so that keeping track 3
of it is a fulltime job.
4 MR. GOSSICK: I think this is a subject certainly, 5
if we get to the Congress with our supplemental request, 6
there is going to be interest in. And I would like to point l
7 to whatever steps we can take between now and then, not only 8
actions, but the management of those actions.
9 COMMISSIONER AHEARNE:
Certainly, it is entirely, 10 as far as I can see, up to Lee if he wants to have an II assistant in his office doing that coordination, that's fine 12 with me.
)
13
.I doubt that it is going to be an adequate response Id overall to have one person try to coordinate this. There is 15 a lot of problems in the coordination.
IS I agree with Vic, I think we are going to have 17 to at some point get to some additional restructuring of 18 those functions. But as a very short-term interim, certainly l9 that's -- (Inaudible.)
20 CHAIRMAN HENDRIE: All right.
21 May we go on that basis, with the understanding 22 that you will look to the matter of what alternate structures 23 might be better than the ones we have now to manage the 24 business.
And wiem then, you cut off the transfer.
That is, Ace. Federal Recorters, Inc.
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mm17 some of which trickle a long way down into the detail work of i
l 2
the shop.
You just can't take the whole thing out. You may 3
take just the planning elements out, or even some more than 4
that.
But you have to decide where that cut line is that you i
5 are going to transfer over into a separate office.
6 And what does that mean in terms of resources?
- And, 7
are you ending up in turn now making emergency planning -- just 8
how does it fit in terms of agency priorities and the overall 9
resource allocation.
10 MR. GOSSICK:
I would ask Norm Haller to take this Il -
l on like he did the safeguards consolidation study on the 12 organizational studies.
And this is a four-bodied problem 13 in that two-bodied problem essentially, and it will take, I'm 14 not sure how much time required.
Something in the nature of 15 a few weeks to do.
I6 CHAIRMAN HENDRIE:
My guess is it will be more than 17 that by the time we sort things out, and interact with the 18 offices.
19 COMMISSIONER AHEARNE:
In theory there is a 20 fair amount of thought that's already been given, I'm sure, 21 to the various aspects of it on the task force.
22 For me, I would like to thank Tom and the people 23 that worked on this.
This is certainly a very significant l
24 piece of work with a lot of hard effort, obviously, to bring j
Ace.Foceral Reportsrs, Inc.
25 us a good way forward on this very difficult subject.
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CHAIRMAN HENDRIE: Yes, I would like to join t hat 2
sentiment.
Thank you very much.
l i
3i MR. GOSSICK:
One last request is that when you I
4 respond to Sam on this, please remember that we have the l
5 Brooks letter to answer. In the report we have got to tell I
6 the Congress what the Commission intends to do.
7 So, if the Commission generally endorses the 8
report, fine, or whatever.
We need to have your guidance.
9 COMMISSIONER AHEARNE: We have the Lone Ranger l
10 working on it.
11 (Laughter) 12 (Whereupon, at 5:30 p.m.,
the hearing in the c..d 14 &l5 13 above-entitled matter was adjourned.)
14 15 16 17 18 19 20 21 22 23 24 Am-Federet Reporters, Inc.
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