ML19249E830
| ML19249E830 | |
| Person / Time | |
|---|---|
| Issue date: | 09/10/1979 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML19249E813 | List: |
| References | |
| REF-10CFR9.7 SECY-79-499, NUDOCS 7910020529 | |
| Download: ML19249E830 (27) | |
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September 10, 1979 I
C 0 R R E C T I O N N 0 T I C E TO ALL COPY HOLDERS OF s
SECY-79-499 - REPORT OF THE TASK FORCE ON EMERGENCY PLANNING
- COMMISSIONER ACTION ITEM)
AT THE REQUEST OF THE TASK FORCES' CHAIRMAN PLEASE REPLACE PAGE 2 0F ENCLOSURE 3 "NRC ACTION PLAN FOR EMERGENCY PREPAREDNESS" TO ENCLOSURE 5 -
" FINAL REPORT OF TASK FORCE ON EMERGENCY PLANNING", WITH THE ATTACHED.
SECRETARIAT ATTACHMENT:
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1071 257
Revised September 4, 1979
-2 (Corrected dates underlined)
One must presume that the long-range action plan will steer between these two extremes.
Above all, we should be reluctant to set deadlines which are too short, or to promise more than we can deliver.
Any change in rules will have no real impact until regulations and guidance have been coupled with a trained staff capable of implementing the objectives of that rule.*
II.
Sumary and Conclusions It is generally accepted that recommendations for short-run actions by the NRC to include final publication of a new rule, should be completed by the end of calendar year 1979. The duration of the period of long-term actions by which NRC will implement and enforce the new rule has not been set.
It can be inferred, logically, from a review of current legislative proposals, that NRC will have to demonstrate an increased ability to evaluate the adequacy of State-local-licensee plans for emergency response by no later than June of 1980, and have a long-run action plan and schedule developed prior to that time.
Table 1 is a proposed schedule which generally describes the decision points and milestones which must be met if the Comission's intention for short-run action is to be met.**
Recomendations for development of a long-range plan of action are discussed in Section VI. of this report.
TABLE 1 PROPOSED SCHEDULE FOR SHORT-TERM EMERGENCY RESPONSE ACTIONS 17 July Federal Register notice of proposed rulemaking.
10 August Final report to the Comission by the Task Force on Emergency Planning.
Task Force on Emergency Planning is dissolved.
31 August End of public coment period on notice of proposed rulemaking.
21 September SD forwards analysis of public coments on notice of rule-making to include suggested modifications to Appendix E.
(Comission briefing) 1 October Comission completes review of draft rule.
9 October Draft rule published for 45-day comment.
21 September SD initiates recomended revisions to Parts 30, 40, 50, and 70 to and Ragulatory c2uldes 1.101, 3.42, and 2.6.
IE revises 31 October Manuci Chapter 0502.
23 November Coment period on rule closes.
14 December SD completes analysis of coments and incorporates into a final rule.
(Comission briefing) 17-31 December Comission completes review of final rule.
}g 8 January Final rule published.
- See " National Planning for Peacetime Nuclear Emergencies (PNE) 1975-1979,"
submitted separately to Lie Comission July 17, 1979, for more on difficulties in emergency planning and preparedness.
- This schedule agrees basically with guidance in a memo, Chilk to Gossick, July 31 1979, subject:
"Comission Guidance on Emergency Planning Rulemaking."
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Aucust 21, 1979 SECY-79-499 dV V 60 COMMISSIONER ACTION For:
The Comissioners From:
Lee V. Gossick Executive Director for Operations
Subject:
REPORT OF TASK FORCE ON EMERGENCY PLANNING
Purpose:
To obtain Comission action on the recomendations of the Task Force on Emergency Planning.
Discussion:
The Task Force on 2mergency Planning was established in June 1979 to identify weaknesses in NRC's emergency preparedness process and to outline an approach for improving NRC's overall emergency preparedness activities.
The Task Force Report, submitted on August 9,1979, is provided as Enclosure 5.
The report is being placed in the Public Document Room and will be published shortly as a NUREG document.
To assist the Comission in its review of the Task Force Report, MPA has summarized the issues, problems, and tasks described in the report.
This sumary is provided as Enclosure 1.
As one of its major efforts, the Task Force developed a list of 14 emergency planning issues (Enclosure 2).
Public coment on these issues was solicited in a July 17, 1979 advance notice of pr: posed rulenaking.
Coments will be analyzed and incorporated into a draft rule that will follow the usual rulemaking process.
The final rule is expected to be published January 15, 1980.
Contact:
E. Hayden, MPA 49-27721 k0
. Two closely related issues particularly relevant to.the rulemaking involve the possibility of making the operation of nuclear power plants contingent upon NRC-approved State and local emergency plans.
These issues would apply to reactors already in operation and to those being built. The other 12 issues can also be associated with current emergency preparedness problem topics identified by the Task Force.
The Task Force identified 30 such problem topics in analyzing NRC's current emergency preparedness process.
These problems are listed in Enclosure 3.
Each office developed specific tasks for resolving these problems.
A list sorting all office tasks into the 30 probl~n topics is provided as.
MPA will track progress on the tasks through the Decision Unit Tracking System.
The office tasks involve short-tem actions, some of which are already underway, and long-term tasks that fom the basis for developing a comprehensive long-range plan for all of NRC's emergency prepared-ness activities.
Management and coordination of these office efforts will be needed to assure that they are coordinated and integrated into a single, coherent agency plan to deal with cmergency preparedness problems.
The Task Force Report indicates the need for 44 additional people to accomplish the tasks laid out by each office. The Task Force's Report was completed before the Comission's review of NRC's FY 1980 supplemental and FY 1981 budget.
Consequently resource requirements identified in the Task Force Report differ somewhat from those described in the budget presentations.
Because the offices have already started working on many of the tasks identified in the report, the Task Force's recomendations require prompt Comission attention.
It is particularly important to determine what technique we should use to assure effective management and coordination of an integrated emergency preparedness program.
For exangle:
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, 1.
Should NRC emergency preparedness oversight be handled by an ad-hoc comittee?
If so, what NRC offices should be represented on the comittee?
2.
Should a separate organization be fonned and assigned the lead for emergency preparedness?
3.
Should a new position be created for a "Tecanical Assistant to the EDO for Emergency Preparedness?"
4.
How should an integrated,long-range plan for emergency preparedness be developed and implemented?
Scheduling:
We are tentatively scheduled to present a briefing on the Task Force Report and its recomendations during the week of September 10th.
Recomendation:
That the Comission consider the recomendations of the Task Force as soon as practicable.
$1 L/ Lee V. Gossick Executive Director for Operations En:losures:
1.
Sumary of Final Report of Task Force on Emergency Planning 2
Issues for Consideration in Rulemaking 3.
Problems Identified by Task Force 4.
Office Tasks Sorted by Problem 5.
Final Report of Task Force on Emergency Planning
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Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Friday, September 14, 1979.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Seotember 5, 1979, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissicners Commission Staff Offices Exec. Dir. for Opers.
ACRS Secretariat I
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MPA Summary' of Report of Task Force on Emercency Planning In June 1979, the ED0 established the Task Force on Emerg to the THI-2 accident, recommendations from a GA0 report,pcy Planning in response and various petitions for rulemLking from interest gro;.ps.
The Task Force was asked to develop a list of major issues to be considered for proposed rulemaking, examine NRC's current emergency preparedness process, and recommend an approach to NRC's overall emergency
'lanning activities.
The Task Force identified fourteen issues that were published for comment on July 17,1979 in the Federal Register in an advance notice of proposed rulemaking.
After analysis of public coments, SD will draft a rule that will follow the usual rulemaking process. The final rule is expected to be published January 15, 1980.
The rulemaking issues concern broad aspects of emergency planning, such as:
should NRC concurrence in State and lomi plans be required for a reactor to operatc; what should be the objectives of ems jency planning; how can financial assistance be p ovided to State and local governments; what should be the requirements for evacuation plans and drills; what should be the criteria for emergency plans; and how : hauld Federal, State, local, public, and licensee emergency response efforts be integrated? Particularly relevant to rulemaking are the issues pertaining to concurrence in State and. local plans. The other issues can be associated with current emergency planning problems identified by the Task Force.
The Task Force identified 30 problems in examining NRC's current process.
These problems lie in six areas of concern to NRC:
(A) responsibility and authority of emergency planning agencies; (B) the planning process; (C) appropriate pre-paredness regulations and guidance to licensees and Federal, State, and local governments; (D) the licensing process; (E) emergency response implementation; and D ) emergency response testing and verification capability.
Individual off.es used these problems as a basis for laying out specific remedial tasks.
The short term tasks are expected to be completed by January 1,1980 and long-term ones by 1984.
Resources I
The Task Force identifies the need for 44 additional people.
These people are needed for the fSilowing activities:
E" Areas Around Nuclear Facilities Should be Better Prepared for Radiological Emergencies," March 1979.
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a (cont.) People Office Activity 8
NRR Evaluation / Instruction Tearrs 7
NMSS Environmental radiation and emergency support 19 IE 5 watch officers; 10 regional inspectors; 4 for planning and operations support.
8 SP Quasi-regulatory field activities and inter-agency planning and coordination.
2 SD Restructuring of regulations The Task Force Rerort recommends:
1.
Give prompt high-level manageme1t attention to emergency preparedness activities.
2.
Establish a comittee to integrate, coordinate, and direct NRC's emergency pre-paredness activities and assure publication of rule by Jan>ary 15, 1980. The life of the comittee should be for 2 years.
3.
Create a pos. tion, entitled, " Technical Assistant to the EDO for Emergency Pre-paredness" to chair the comittee or as an alternative elect a chairman from the comittee.
4.
Develop an integrated, comp. :hensivg long-range plan for all of NRC's emergency preparedness activities.
5.
Disband the Task Force because it has fulfilled its responsibilities and lacks authority to compel sustained interoffice participation.
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14 ISSUES FOR CONSIDERATION IN RULEMAKING p1 (published in FRN July 17,1979) l.
Basic emergency planning objectives 2.
Effective emergency response plan contents and guidance 3.
State and local emergency plan requirement for continrd operation 4.
State and local emergency plan requirement for new license 5.
Financial assistance to state and local governments 6.
Emergency response drill requirements 7.
Notification of public prior to emergency 8.
Actions in response to recommendations in NRC/ EPA Task Force report
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Incident / emergency notification criteria 10.
State / local / licensee influence on f Jeral emergency plans 11.
Federal, state and local government interface during an emergency 12.
Radiological emergency response training responsibilities 13.
Reliance placed on licensee for assessing consequences of accident 14.
Public partipation in emergency response drills 1071 267
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enclosure 3 30 Problems of Current NRC Process Identifieo oy tne Tasx Force on tmergency Planning Lead Office A.
Resconsibility/ Authority l.
NRC's statutory responsibilites in FRPPNE unclear SP 2.
Interagency coordination ill-defined SP/IE 3.
Funding of State and local agencies to support EP*
SP not integrated 4.
Transportatior; EP inadequate NMSS 5.
NRC role in EP inadequately defined IE 5.
Licensee responsibility for offsite EP exceeds NRR/NMSS author'ty B.
Plannino Process 1.
NRC efforts currently fragmented EDO 2.
Incident Response Program incomplete IE 3.
Consideration of Class 9 accidents in licensees' NRR/NMSS plans not required 4.
NRC responsibility in FRPPNE not implemented SP 5.
EP research not comprehensively evaluated SP 6.
No NRC control over resources of other agencies SP assigned to RAC C.
Reculations and Guidance 1.
NRC Et> guidance non-specific NRR/NMSS/SP 2.
EP regulations.and their application inconsistent SD and incomolete.
3.
Protective Action Guides not uniformly ada sed or SP implemented D.
Licensina 1.
Actual offsite capability not fully assessed by NRC NRR/NMSS 2.
NRC concurrence in State plans not related to SP licensing process 3.
Assistance to States not formally coupled to SP licensing process 4.
Generic treatment of EP issues in public SD hearings lacking E.
Imolementation 1.
Coordination of Federal response affecting licensed SP/IE facilities insufficient 2.
Inspection and licensing EP efforts not closely NRR/NMSS/IE integrated 3.
Upgrade of operating facility plans to current criteria NRR/NMSS 4.
Incident response criteria for notifying NRC too loose IE/SD S.
NRC response capability not fully established IE EP = emergency preparedness 10/1 2M
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Imolementation, cont'd.
6.
Near-to-site facility for response personnel non-IE/EDO existent 7.
NRC monitoring capability inadequate NRR/NMSS/IE 8.
Procedures for informing public of accident ED0/PA status inadequate F.
Testino and Verification Cacability 1.
NRC-wide audit of EP non-existent EDO 2.
Criteria for drills undefined NRR/NMSS/SP 3.
Continued evaluation of training and qualification SP of State and local personnel non-existent 1071 270
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Enc osure Office Tasks Sorted by Problem A.
Responsibility / Authority Comoletion Problem A-1 FRPPNE SHOULD BE CLARIFIED WITH RESPECT TO NRC'S STATUTORY RESPONSI3ILITIES SP Tasks _,
a.
Query PEMA on status of FRPPNE Immediate b.
If FRPPNE still operative, review FRPPNE and Atomic Imrediate Energy Act for potential conflicts; propose changes.
If FRPPNE is not operative, use results of*b."
- Immediate c.
in NRC contribution to any successor to FRPPNE.
d.
Work with FEMA to develop the President's " National Early 1980 Contingency Plan;" take position that the " National Contingency Plan" replace FRPENE, and perhaps IRAP.
Problem A-2 FORMAL ARRANGEMENTS ARE ILL-DEFINED FOR INTER, AGENCY (FEDERAL, STATE, AND LOCAL) COORDINATION.
THE PROCESS CURRENTLY IS ON A VOLUNTARY SASIS.
.SP Tasks - FRPPNE a.
Outline what agencies should be involved in Federal Immediate coordinated radicicgical emergency response and hcw coordination should take place.
Seek other agencies' agreement ",
b.
Outline how Federal agencies should relate to and Immediate coordinate with State and local government agencies in such an emergency response.
Seek other agencies' agreement.
c.
Use comments on Advance Notice of Proposed Rulemaking Immediate for other ideas on respective roles and coordination of Federal, State, and local governments.
d.
Complete NRC agency response plan.
March 1980 e.
Stake out prominent role for NRC in development of the Early 1980 National Contingency Plan under FEMA leadership.
f.
Work with FEMA to seek a consensus among State and Early 1980 local governments in radiological emergency response and include this consensus in NRC and National Con-tingency Plan.
g.
Include appropriate language in NRC regulations March 1980 related to State and local radiological emergency response plans.
Meet with Forest Service concerning support.
August 1979 b.
Identify problems re TMI-2; IRAP agencies and others September 197 meet.
c.
Revise and rewrite IRAP.
,}
Long Term
Comoletion Problem A-3 THERE IS NO INTEGRATED FEDERAL MECHANISM FOR THE FUNDING OF STATE AND LOCAL AGENCIES TO SUPPORT RADIOLOGICAL EMERGENC) PREPAREDNESS
, SP Tasks a.
Complete the NRC Funding Study (Saloman Report, NUREG-Immediate 0553).
b.
Based on Saloman Report, outline options for future Intediata action by NRC and FEMA.
c.
Request FY 80 budget supplemental to assist States Immediate and local governments, d.
Develop proposed rulemaking or legislation to resolve December 1980 the funding problem.
r Problem A-4 RADIOLOGICAL EMERGENCY RESPONSE PLANNING FOR TRANSPORTATION ACCIDENTS IS INADEQUATE NMSS Tasks a.
Urge DOT to do rulemaking to install the necessary Long Term regulations for augmenting transportation safety, b.
If "a" is unsuccessful, seek legislative authority Long Term to effect the recommendations of the NRC/ DOT Task Force in NUREG-0535.
NRC HAS NOT ADEQUATELY DEFINED ITS ROLE IN Problem A-5 EMERGENCY RESPONSE IE Tasks a.
Coordinate with NRR, NMSS, and SP on development of Short-T' era work statement to define spectrum of potential NRC roles.
b.
Prepare report on NRC role.
June 1980 c.
Prepare Commission discussion paper on NRC role.
Long Term Problem A-6 THE LICENSEE'S RESPONSIBILITY EXCEEDS HIS AUTHORITY WITH RESPECT TO OFFSITE EMERGENCY PLANNING NRR Tasks - Reactors This area is not to be specifically addressed in the NRR action plan.
NMSS Tasks - Fuel-cycle Facilities a.
Exact through licensees the necessary arrangements March 1980 for supporting activities of State and local agencies having emergency response roles.
b.
Exact through byproduct material licensees the October 1980 necessary arrangements for supporting activities of
[3 Sta'e and local agencies having emergency response 071 276 B.
Planning Process Comoletion Problem B-1 FOR THE EMERGENCY PLANNING PROCESS, NO EFFECTIVE MECHANISM EXISTS WITHIN NRC FDR ASSURING CONSIS-TENCY AND THE INTEGRATION OF GUIDANCE, i.e., THE-EFF03T IS CURRENTLY FRAGMENTED EDO Tasks a.
Recognize lead offices for the following areas of res-Short Term ponsibility:
NRC ccmmend and control, including the Incident Response Center (IE)
Radiological monitoring including equipment iden-tification and development of IRACT response (IE)
Site licensing including retroactive actions and new rule development (NRR or NMSS)
Training and staff assistance to licensees and State and local government (SP)
Public information policy during emergencies (PA) b.
Establish an emergency preparedness organization to Sho;-t T erm provide a focal point for staff action.-
Problem B-2 NRC INCIDENT RESPONSE PROGRAM NEEDS EXPANSION AND FURTHER DEVELOPMENT.
IE Tasks a.
Upgrade Operations Center comunications.
August 1979 b.
Improve Operation 3 Center heating, ventilating, and
~
air conditionii.9 August 1979 Revise Manual Chapter OE02 without defining NRC's role.
October 1979 c.
December 197 d.
Upgrade Operations Center furniture.
December 197 Upgrade Operations Center audiovisual support.
e.
December 197 f.
Upgrade Operations Center support staff.
g.
Incorporate appropriate national-level planning Short Term in guidance.
h.
Increase incident response program manpower by 2 Long Term i.
Upgrade Operations Center to handle data input (pe:r Long Term Sandia Study).
J.
Expand Operations Center to adequately support incident Long Term response activities on extended bais.
k.
Upgrade recording capabilities; revise telephone system.
Long Term 1.
Upgrade field communications.
Long Term m.
Develop rulemaking to determine who pays for communi-Long Term cations at licensee sites.
S -
(
10,/1 D
9 n
Comoletion Problem B-3 THE '.ICENSEE'S PLANNING IS BASED ON ACCIDENTS OF i'
SEVERITY UP TO AND INCLUDING THE MOST SERIOUS DESIGN BASIS ACCIDENTS.
NRR Tasks - Reactors a.
Revise pioposed changes to Appendix E to reflect NUREG-Short Term 0396 guidance; backfit Regulatory Guide 1.97 from TMI lessons learned.
b.
Determine instrumentation needed to follow the course Long Term of an accident in support of SD revision of Regulatory Guide 1.97.
NMSS Tasks - Fual-cycle Facilit,ies a.
Assess 10 CFR Part 70 emergency plans for adequacy in Short Term dealing with accident situations more severe than the design basis accidents; Backfit plans where needed (Schedule same as E-3)-
Long Term b.
Request selected Part 30 and.40 licensees to submit July 1950 emergency plans addressing severe accident situations.
c.
Establish through rulemaking requirements for emergency July 1981 plans to deal with more severe consequences than the accidents considered in the Safety Evaluation Reports prepared in support of licensing actions.
Problem B-4 THE NRC RESPONSIBILITIES DELINEATED IN FRPPNE HAVE NOT BEEN IMPLEMENTED WITHIN THE NRC.
SP Tasks a.
Determine if FEMA expects NRC and other Federal agencies Immediate to do planning outlined in FRPPNE. (See A-1) b.
Take position that " National Contingency Plan" replace Early 1980 FRPPNE and perhaps IRAP (See A-1),
c.
Prepare NRC agency plan and work with FEMA to develop Immediate the President's ' National Contingency Plan."
d.
Start work on NRC agency response plan and the " National Immediate Contingency Plan" called for in the Senate NRC Authori-zation Bill.
e.
Assure that the NRC agency plan is compatible and is Early 1980 an appropriate part of the " National Contingency Plan."
~
Problem B-5 THE NEED FOR RESEARCH OR STUDIES IN THE EMERGENCY RESPONSE AREA HAS NOT BEEN COMPREHENSIVELY EVALUATED.
SP Tasks a.
List completed and ongoing emergency preparedness studies Immediate conducted in andfor NRC.
b.
Determine what emergency preparedness studies are ongoing Imediate or completed at other Federal agencies, g
c.
Seek NRC proposals for additional research studies. 1071 2 7 peesate
5-Comoletion SP Tasks, cont'd.
d.
Prepare research study proposals identified in "c."
September 198 e.
If required prepare additional research study pro-Long Term posals on e,mergency preparedness identified by TMI investigative groups.
Problem B-6 NRC HAS NO CONTROL OVER OTHER AGENCY RESOURCES ASSIGNED TO THE REGIONAL ADVISORY COMMITTEES (RAC'S)
SP Tasks a.
Send letters to appropriate Federal agencies to recommit Immediate regional resources in terms of people ad funds for RAC's.
b.
Have FEMA possibly reestablish the RAC's on a formal basis June 1980 for all-htzards emergency planning.
c.
If "a" and "b" are unsuccessful in improving the control Long Term situation, consider legislative remedy.
C.
Reculations and Guidance Problem C-1 NRC EMERGENCY PLANNING GUIDANCE NEEDS IMPROVEMENT NRR Tasks - Reactors a.
Elaborate in Regulatory Guide 1.101 on uniform action July 1980 level criteria.
NMSSTasks-Fuel-cycbFacilit_ies a.
Establish an interim position on requirements for non-Longl'erm reactor licensee emergency plans.
b.
Modify Regulatory Guide 3.42, Revision 1.
July 1981 c.
Extend requirements for emergency planning to other December 1981 Part 70 licensees and to Parts 30 and 40 licensees; develop and promulgate appropriate guidance.
SP Tasks a.
Develop acceptance criteria for existing State and local Immediate government emergency planning guidance, b.
Provide standardized scenarios to test licensee, State, Immediate and local government emergency plans.
c.
Prepare letters to other Federal agencies encouraging Immediate them to complete their guidance documents.
d.
Carry over the acceptance criteria concept into regu-June 1980 lations in accordance with expected legislative mandate.
e.
Develop improved guidance handbook for Federal agency June 1980 assistance activities with the States.
f.
Prepare an improved guidance document for the States June 1980 and local governments.
1071 276 Comoletion Problem C-2 REGULATIONS HAVE VOIDS OR INCONSISTENCIES RELATED TO EMERGENCY PLANNING.
I SD Tasks a.
(Require Part 50 and Part 70 licensees to maintain cur-Short Term
)
rent emergency plans and require research reactors to submit an emergency plan for NRC review a.1d approval.)
b.
Evaluate the need for an " Appendix E" for Part 30 and Long Term Part 40 licensees.
Problem C-3 PROTECTIVE ACTION GUIDES (PAG's) HAVE NOT BEEN PROMULGATED AS OFFICIAL FEDERAL GUIDANCE.
SP Tasks a.
Prepare letters to EPA and HEW urging prompt action on Immediate converting " Agency guidance" PAG's to official Federal guidance PAG's.
D.
Licensina Problem 0-1 DURING THE LICENSING PROCESS, NRC DOES NOT FULLY ASSESS ACTUAL OFFSITE CAtABILITY BUT LIMITS EXAMIN-2 l
ATION TO THE PLEDGES OF RESOURCES.
NRR Tasks - Reactors a.
Assess offsite capabilities in licensing process Short Tenn SMS' Tasks - Fuel Cycle Pacilities S
a.
Establish locations of existing State and local capa-March 1980 bilities to cope with emergencies at licensee locations.
b.
Categorize licensees based on offsite impacts; set priorities for action and assign required offsite response needs to each.
October 1980 c.
Assess and confinn the offsite capabilitim by actual Long Term inspection art discussions with licensees and State and local agencies, d.
Assist all parties in developing adequate emergency Long Term plans.
Problem D-2 THE NRC " CONCURRENCE" RELATED TO STATE PLANS IS NOT DIRECTLY RELATED TO THE LICENSING PROCESS.
SP Tasks a.
Push for plan concurrences in States that have operating Immediate nuclear power plants using existing guidance and pro-cedures.
b.
Begin codifying existing guidance into regulations.
Immediate c.
Complete above tasks in accordance with time frames June 1980 specified in expected legislation.
} ()~ J 2 [ /
June 1980
/
d.
Shift from a concurrence process to an approval process using the new regulations.
_y.
Comoletion THE ASSISTANCE TO STATES IS NOT FORMALLY COUPLED
.' Problem D-3 TO THE LICENSING PROCESS.
SP Tasks The emergency preparedness assistance procram need not be coupled to the licensing process.
Problem D-4 BECAUSE OF THE LACK OF A GENERIC TREATMENT OF EMERGENCY PLANNING ISSUES IN PUBLIC HEARINGS, THE SAME CONTENTIONS REPEATEDLY OCCUR IN PUBLIC PROCEEDINGS AND PLACE AN UNDUE BURDEN ON THE STAFF.
SO Tasks a.
To ensure generic treatment of emergency preparedness issues:
1.
Revise or develop Regulations and Regulatory Guides.
Short Term
- Appendix E, Guide 1.101, and Guide 1.97 A proposed regulation requiring concurrence in State / local plans as a condition for power reactor licenses.
A proposed regulation requiring joint test exercises once each five years and within one year of initial plant operation.
Revisich 2 of Guide 1.89 on qualification of equiment.
A proposed rule or policy statement on the emergency planning feasibility in considering alternative sites in the licensing process.
2.
Resolve Critical Mass Petition for Rulemaking, October 1980 revise Reg. Guides 1.101, 3.42, and 2.6.
3.
Develop emergency preparedness regulations for October 1981 research reactors and reassess regulations for Part 70 and Part 30 licensees.
E.
Implementation Problem E-1 INSUFFICIENT NRC ATTENTION HAS BEEN GIVEN TO COORDINATING THE CEDERAL RESPONSE AFFECTING LICENSED FACILITIES.
SP Tasks "RPPNE Tied to other actions ores dealing with FRPPNE and Short Term IRAP and with NRC's incident response program in A-1, A-2, and B 4 IE Tasks - IRAP See A-1, A-2, and 3-4.
1071 278
8-Comoletion
. Problem E-2 LICENSING AND INSPECTION RESOURCES NEED EXPANSION TO BETTER IMPLEMENT THEIR EMERGENCY PLANNING EFFORTS.
NRR Tasks - Reactors Evaluate licensee plans against current criteria (.E-3).
Short Term Budget process to support Reg. & guide Changes, offsite Long Term monitoring, information gathering NMSS Tasks __ Fuel-cycle Faci.4 ties a.
Install an Environmental Radiation and Emergency Support Fall 1979 Section (ERESS) that will guide and coordinate NMSS activities relative to emergency preparadness.
IE Tasks
~
Annually observe licensee emergency plan drills for power Short Term a.
reactors.
b.
Revise manual procedures based on results from initial April 1980 inspections, c.
Evaluate State agency readiness:
Develop procedures for evaluating State agency performance.
Annually conduct evaluations as part of routine inspections.
d.
Develop emergency preparedness activity requirements for material licensees:
Identify categories of licensees that should be included.
October 1979 Develop and improve requirements ( A/M55)
January 1980 Develop procedures for inspecting licensees July 1980 Commence inspe:tions.
October 1980 Problem E-3 THE MAJORITY OF OPERATING FACILITIES HAVE NOT BEEN EVALUATED AGAINST THE STAFF'S CURRENT CRITERIA FOR EMERGENCY PLANNING.
NRR Tasks - Reactors Evaluate licensee plans aoainst current criteria Short Term NMSS Tasks - Fuel-cycle Facilities a.
For those NMSS licensees already required to have approved emergency plans:
Short Term Define current criteria Review existing requirements, guidance, and licensee Short Term plans and define deficiencies 1071 279
- g-Comoletion NMSS Tasks b.
For those NMSS licensees not presently required to have approved emergenc'; plans:
Seek short-term remedies in existing regulations and Short Tem guides.
Implement short-term remedies for high-risk licensees Short Term by Branch positions or mutual agreements with licensees.
c.
Develop requirements for approved emergency plans for December 1980 activities licensed under Parts 30, 40, and 70 and install through rulemaking Develop and promulgate necessary guidance.
July 1981 Problem E-4 THE INCIDENT RESPONSE CRITERIA FOR TIMELY NOTIFI-CATION OF THE NRC NEED TO BE TIGHTENED.
IE Tasks - Criteria a.
Adjust criteria based on responses by licensees until Short Term appropriate type and degree of information is obtained.
b.
Revise procedures for handling information within NRC Short Term c.
Revise HQ Incident Response Plan and inform licensees Long Verm of revisions.
SD Tasks - Regulations a.
Review and analyze NRC's current rules, records, and Unspecified practices involved in petitioner considerations.'
Radioactivity in effluents to unrestricted areas Notifications of incidents Emergency plans fcr production and utilization facilities Emergency plans for production and utilization facil-ities Emergency plans fer Part 50 and Part 70 licensees Regulatory Guides 1.101 and 1.16, Appendix A.
Problem E-5 AN ORGANIZED " FACILITY CLASS ORIENTED" NRC RESPONSE CAPABILITY HAS NOT BEEN FULLY ESTABLISHED.
IE Tasks a.
Identify incident response organization both at hQ and Short Term site.
b.
Begin exercise program to retain proficiency gained during March 1980 TMI-2 experience.
10/1 200 Completion THERE IS A NEED DURING AN ACTUAL EMERGENCY FOR
, Problem E-6 NEAR-TO-THE-SITE FACILITY TO HOUSE THE MULTI-AGENCY COORDINATION AND RESPONSE SUPPORT ACTIVITY IE Tasks a.
Integrate site support and functions with Regional '
Short Term e
Office response b.
Identify operational and support requirements and Short Term have ADM make prearrangements to obtian. support during incidents; incorporata in Incident Response plans.
c.
Based on definition of NRC role; revise existing Long Term support capabilities.
EDO Tasks a.
Likely designate IE lead office.
Long Tenn b.
Define emergency preparedness responsibilities to Long Term avoid overlap; coordinate IRAP and 00E resources
'c.
Integrate drills or tests of response plans into Long Tem the program.
d.
Explore modular concepts for facility.
Long Term e.
Give priority to radiological monitoring.
Long Term f.
Assign NMSS and NRR responsibility for providing Long Term technical personnel and equipment for mobilizaticn of the response teams.
Problem'E-7 NEED EXISTS FOR EXPANDED NRC MONITORING t
CAPABILITY NRR Tasks - Reactors a.
Develop lists of parameters needed for expanded moni-Short Term toring capability NMSS Tasks - Fuel-cycle Facilities a.
Survey licensee activities having the potential for Short Term significant offsite adverse impacts due to accidents, sabotage, or severe natural phenomena through a survey questionnaire.
b.
Analyze data for possible NMSS-unique monitoring Short Term requirements.
c.
Equip NRC response teams to assess environmental Long Term contamination resulting frcm unplanned releases from NMSS-licensed activities.
d.
Identify likely contaminant isotopes and levels as t.cng Term part of licensee emergency plans to be required by regulation.
e.
Convey any special monitoring needs for evaluation Lcng Term and implementation to IE.
10/l 2Ci
'. Comoletion
'i;. IE Tasks a.
NRC offices will identify areas where expanded NRC monitoring capabilities are necessary:
Define operational parameters January 1980 Define environmental monitorin capability October 1979 Define plant discharge monitoring needs January 1980 b.
Procure equipment and 6evelop procedures for use:
Place TLD's around operating power reactors January 1980 Collect NRC's TLD's.
January 1980 Order monitoring equipment April 1980 Develop budget supplement not included in above.
April 1980 c.
Procure equipment / data links for NRC Incident Response Center:
Procure operational parameters April 1980 Procure plant discharge monitors July 1980 Problem E-8 PROCEDURES FOR DISSEMINATION OF PUBLIC INFOR-MATION ARE NOT ADEQUATE EDO Tasks a.
Coordinate development plan for information policy during future'. emergencies:
Designate a primary NRC spokesman Short Term Issue a pre-announced schedule of statements, press conferences, and bulletins; discusssource term monitoring results; buildup of emergency response assets; relationships with cooperating agency spokesmen, State and local designated spokesmen, and licensee spokesmen; specific areas of NRC lead authc"ity.
F.
Testing and Verfication Capability Problem F-1 THERE HAS NEVER BEEN AN NRC-WIDE AUDIT OF THE EMERGENCY RESPONSE FUNCTION ED0 Tasks a.
Make a self-audit of the agency emergency preparedness December 198 program.
Problem F-2 EVALUATION CRITERIA FOR DRILLS / EXERCISES ARE NOT DEFINED NRR Tasks - Reactors 1071 232 Snc, rer, a.
Develop criteria for joint exercises.
NMSS Tasks - Fuel-cycle Facilities a.
Possible second review of post-licensing emergency Short Term plans for fuel-cycle facilities Ccmoletion riMSS fasks (continued) b.
Review emergency plans suomitted in support of Short Term renewal applications c.
Integrate renewal application criteria with devel-Long Term opment of criteria for review of rew emergency plans.
d.
At five-year intervals, reevaluate emergen:y plans Long Term against up-to-date criteria, e.
Develop and/or adopt from NRR, criteria anc' procedures Long Term for post-licensing reassessment of emergency support capabilities.
Problem F-3 THERE IS NO EFFECTIVE NRC MECHANISM FOR CONTIN-UED EVALUATION OF THE TRAINING AND QLALIFICATION OF KEY STATE AND LOCAL EMERGENCY RESPONSE PERSONNEL
~ SP Tasks a.
Determine the actrition of NRC-trained emergency Imediate response personael since M uch 1975.
b.
Determine training and replacement training nteds of Imediate States and local governments for the next five years, c.
Establish Federal mechanism to certiTy emergency June 1980 planning and 'esponse personnel.
d.
Establish re-training programs.
September 198 e.
Establish addi.tional required training programs.
December 1980 101\\ ^U