ML19249E840
| ML19249E840 | |
| Person / Time | |
|---|---|
| Issue date: | 08/09/1979 |
| From: | Ted Carter NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19249E813 | List: |
| References | |
| REF-10CFR9.7 SECY-79-499, NUDOCS 7910020545 | |
| Download: ML19249E840 (23) | |
Text
{{#Wiki_filter:. p-J, AUG 9 1979 e MEMORA!!DUM FOR: Chaiman Hendrie. Cormissioner Gilinsky Mp g3 Cornissioner Kennedy II I (j Ccenissioner Bradford i I Comissioner Ahearne THRU: Leo V. Gossick Executive Director for Operations FROM: Thomas F. Carter, Jr., Chaiman Task Force on Erargency Planning
SUBJECT:
FI!W. REPORT OF TASK FORCE ON EMERGENCY PLANNING The Task Force on Emergency Planning, which was established by the Comission in its meeting of June 7,1979, was given three general responsibilities: (1) develop for Ccmission consideration a list of major issues for rule-making; (2) describe and objectively critique NRC's current emergency planning process; and (3) define and recomocnd an approach for developing a cc:: pre- ~ hensive plan that would formulate the scope, directf on, and pace for NRC's _ = _ zz 'verall emergency planning activities. '(Specific responsibilities were
=== celineated in a nemorandifd' from Lee V. Gossick dated June 11, 1979, and in a SECY rer:orandum dated June 12, 1979.) lists members of the Task Force and a supporting Working Group. The Task Force has completed its assigned responsibilf ties, and herewith is reporting the results of its activities. The list of najor issues developed by the Task Force was sent to the Comission via memoranduc of June 19, and a discussion of each of the major issues was sent on Jtily 17. The descrip-tion and critique of the current emergency planning pro: css, which was discussed during a Comission briefing held on June 28, is sumarized in. The criti<we produced an extensive set of problem topics, which are also set forth in Enclosure 2. The comprehensive ac'.fon plan (Enclosure 3) presents staff plans for resolving the problem topics contained in Enclosure 2. f._. 6 c) ( 'M __-_+wmt Y m w*, r-
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9 P The Commissioners 1 - 0 U rtl,I Ak M. T. Jamgochian (SD), in consultation with all progran offices, has precare) drafts of croposed amendments to NP.C regulations in crder to resolve many of the problems that have recently surfaced in the emergency preparedness area ~ (Enclosure 4). The Task Force members, recognizing that the specific language of the proposed regulations must be carefully assessed, unanimously supcort the basic principles presented in '!r. Jar;cchian's procesed changes. Since State / local plan concurrence is to be a key factor in the preposed r.egulation changes and will impact en the decisior, to issue a license, serious considera-tion must be given to how this concurrence precess is integrated into the responsibility of the licensing office. Early comments and suggestiens frcm the Ccmmissioners on these proposed amendments would be helpful to SD in pro-mating rapid development of the needed rule changes. p, Tnemas F. Carter, Jr., Chairman T:sk Force on Emergency Planning
Enclosures:
1. List of Members-Task Force and Working Group 2. Description & Critique of HRC's Current Emergency Preparedness Process 3. Comprehensive Action Plan 4 Draft Proposed Adendments to 10 CFR Part 50 cc w/ enclosures: L. Bickwit, OGC S. Chilk, SECY A. Kenneke, OPE G 10/i
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=a =. "~ ' Task Force on Emergency Plannino Members T. Carter, NMSS H. Collins, SP P. Comella, SD J. Durst, RES B. Grimes, NRR J. Hegner, IE W. Houston, NRR M. Jamgochian, SD J. Long, NMSS M. Sanders, SP J. Sniezek, IE D. Thompson, IE R. Voegeli, ELD l=$= Workino Grouc
- .g.5 C. South, Group Leader, NMSS R. DeFayette, SP J. Dukes, SP J. Durst, RES
~: F. Fisher, NMSS H. Gaut, SP J. Hegner, IE G. K11gfield, NMSS F. Lomax, NMSS R. Priebe, NRR M. Sanders, SP J. Sears, NRR J. Sniezek, IE ~ jo/l 266 O
Mh DESCRIPTION AND CRITIQUE OF NRC'S CURRENT EMERGENCY PREPAREDNESS PROCESS *~ As a basis fc? future emergency planning activities, NRC's current emergency preparedness process was systematically described and analyzed for deficiencies or potential weaknesses. The description and critiquing were done by a separate working group consisting of representatives from NRR, NHSS, IE, and SP. Task Force menbers further refined the working group's product of 30 problem topics and used these problem topics to prepare action plans for individual NRC offices. Description of Current Emercency Precaredness Process To achieve an orderly and systematic description of NRC's emergency preparedness activities and to provide a means for an objective critique of that precess, the working group developed a three-dimensional (4 x 4 x 7) matrix containing 112 cells. One dimension of the matrix represented the classes of participants in t.Ne radiological emergency preparedness process: (a) NRC; (b) Licensees; (c) State and local agencies; and (d) Other Federal agencies. The second dimension represented the various phases of emergency preparedness: (a) Planning; (b) Licer sing; (c) Implementation and testing; and (d) Actual emergency response. The third dimension consisted of the folicwing factors: (a) Responsibilities; (b) Limitations; (c) Objectives; (d) Activities (expenditure of resources); (e) Prot ucts, goods, and services; (f) Organization (the entity performing the activities and/or delivering the products for the particular cell under consideration);and (g) Interfaces. Use of this methodology forced a disciplined consideration of the entire emergency preparedness process. Each cell of the matrix was filled in only after detailed
- The Task Force uses the term ' Emergency Preparedness' in preference to the term
' Emergency Planning' because energency preparedness connotes tha. nole of planning, implementation, and execution. 1071 23~7
and scrnetimes lengthy dis'cussion'among members of the working group. Time constraints necessitated use of capsulized descriptions within the cells that were intelligible to members of the ' working group but would not be very meaningful to outsiders. (Meaningful description of a cell's contents would require two or three pages of text, and time was not available for preparing .such a document.) Objective Criticue of Current Process Upon completion of the matrix describing the current emergency preparedness process, members of the working group proceeded to examine each of the cells for deficiencies and weaknesses. This analysis produced a list of 20 problem topics that, for ease of discussion, were grouped in six areas. Problem areas were: (a) Responsibility and Authority; (b) The Planning Process; (c) Regulations and Guidance; (d) Licensing; (e) Implementation; and (f) Testing .;.h and Verification of Capability. ~. . ;.y TFe list of problem topics was' valuable to the Task Force not only because of the systematic basis upon which it was prepared but also because the members of the working group were able to agree on the wording of the problem topics and the supporting descriptions. 4 Subsecuent Use of problem Taoics Given the list of problem topics developed by the working group, the Task Force members modified the. problem wording and descriptions in accordance with their own perceptions, and proceeded to define an approach to resolving the problems. Some problems were believed capable of resolution in the short term (six months or less). Others were seen as taking longer than six months. Still others were identified as amenable to both short-and long-term resolution; that is, some of the identifiable tasks could be done quickly whereas other tasks that were part of the same problem would take considerably longer to achieve. 107i 2dB
On the following list of problem topics a notation indicates whether the Task Force believes the problem can be solved entirely in the short ter:n, partly in the short term,' or will require a longer time for resolution. The 1 list also identifies offices having lead and support roles in effecting resolution of each' of the problem topics. Office " Action Plans" were prepared to describe how the problems would be resolved. For any given problem topic, a look at the action plan for the lead office should indicate how that office expects to effect the resolution. Office action plans are contained in Section VI of the NRC Action Plan. In the listing that foTlows, each problem area is identified by a letter-(A._ through F_). Within each area, each problem topic is identified by a number prefixed by the letter for the area within which it falls, thus: A-1, A-2, etc. Listing of Problem Tooics A_ Resconsibility/Authori ty Six problem topics were identified in this important area of emergency planning and response. Scme of the problems in other problem areas derive from omissions or lack of effective mechanisms described here. 7 In fact,.some of those problems m, not be amenable to solution unless these are corrected first, or at last concurrently. A FRPPNE*shouIdbeclarified Resolution: Long term with resoect to NRC's Lead: SP statu'.ory resconsibilities. Support: NRR/NMSS/IE Under the :RFPNE* division of authority r'or control of Federal re.sponse at a licensed nur. lear facility, the NRC leadership role s reduced to support status as soon as offsite casualties or widespread contamir ation occur. The logic for this choice is that the agencies having resources required to control and mitigate the consequences of a disaster can best manage the total Federal response to an emergency. 10/1 239 It may be, however, that the explicit and implicit cencerns for the public health and safety contained in the Atomic Energy Act would require NRC to maintain
- The FRPPNE (Federal Response Plan for Peacetime Nuclear Emergencies) was pro-mulgated by the Federal Preparedness Agency (now part of FEMA) in April 1977 as interim guidance to Federal agencies in the revision of existing plans and the preparation of any required new plans.
It is guidance for, peacetime nuclear emergency response planning. It is not a Federal response plan, per se. It has not been issued as permanent guidance. With one exception, the planning J5E called for by NRC in the FRPPNE has been done or continues to be done. The exception calls for an NRC plan to rescend to a " Category III" incident where there is widespread radioactive contamination at a licensed nuclear facility in a remote area with limited casualties but significant property damace.
continuina conti11 of many aspects of emergency operations at a licensed nuclear facility, even after offsite contamination and casualties have occurred. A Formal arrangements are ill-Resolution: Short and long tenn oef1neo for interacency (Federal, Lead (FRPPNE): SP State, and local) coore1 nation. Support (FT.PPNE): IE The crocess currentiv Ts on a Lead (IRAP): IE voluntary easis. Support (IRAP): NRR/faiSS/SP Federal agencies recognize the supremacy of State and local goverrments to direct emergency response efforts within their jurisdictions. Those Federal agencies preparing emergency response plans, rules, and reculations have routinely ensured that those documents reflect the prerogatives of State and local authorities. Moreover, the inteccated Federal. emergency response program as it exists *wday gives an almost sinilar sovereignty to the prerogatives and authori' ties of the Federal agencies who cooperate in the emergency planning. Hence, the limits = .-{f of cooperation, c:ord.i. nation, and designation of resources in the planning stage is essentially limited by the decision of each agency. The primacy of State and local. authority in planning for emergency response will (and should) continue to exist, even though it consumes planning resources and ccmplicates national planning. ~ .If the national emergency preparedness effort is to be effective, it must be based on more compulsive legislative mandate that assigns authority and respon-sibility so that the traditional prerogatives and jurisdictions of individual Federal agencies do not limit the ultimate effectiveness of the plan. A There is no inteorated Federal Resolution: Short and long term mecnanism for tne funoing of Lead: SP State ano local acencies to Support: N/A succort raclotoolcal emergency crecareoness. .4 f 10/1 270 ~
-.- =: Other Federal agencies expend resources in assisting, and granting funds for, State and local agencies' general emergency planning. NRC expends resources, ~ not yet including grant funds, to provide assistance ^a State and local agencies e for radiological emergency preparedness. There is no Federal mechanism for integrating NRC's effort with the other resource expenditure efforts. A Radiolooical Emeroency Resconse Resolution: Long tenn Planning for transoortation Lead: NMSS accidents is inadecuate. Support: IE/SP/SD Because of the split and overlap of authority of the NRC and other agencies that - regulate inter-and intrastate transport of licensed nuclear materials, there is no clear designation of responsibility for emergency preparedness functions. This situation is complicated by the fact that shipments involve licensed . shippers anc receivers, government shippers and receivers, and unlicensed carriers. This subject has been discussed in detail in a 1979 GAO draft report, " Nuclear Materials Transportation: Federal Actions Are fleeded to Improve [ Safety and Security." - -? w. A NRC has not adecuatelv defined its Resolution: Short term role in emeroencv resconse. Lead: IE Support: NRR/NMSS/SP/EDO NRC's role has not been. defined in NRC Manual Chapter 0502. The range of response, role from monitoring to operational control was only implicitly addressed in NRC planning and procedures prior to TMI. NRC's response during TMI was an ad hoc response based upon a perceived role. A The licensee's resconsibility Resolution: Short '.enn exceecs nis autnority witn Lead: NRR/NhSS resoect to offsite emercency Support: IE/ST' olannino. NRC requires the licensee's plans to provide reasonable asr.urance that appropriate protective measures can and will be taken to protect the public health and safety. Because neither NRC nor the licensee has authority over offsite resources (even though the licensee may donate equipment and training), the planning process between the licensee and Federal / State / local agencies is voluntary, unenforceable by NRC or the licensee on Federal, State, and local 1071 291
.1.w:= =:- agencies and difficult tb validate. B_ - Plannino Process Six problem topics were identified in the area of the planning process for identifying, developing, or providing emergency planning products, goods, or services. These are, for the most part, internal to NRC; however, some affect--or are affected-b other agencies. B For the emereency olannina crocess. Resolution: Short tenn no effective mechanism exists witnin Lead: EDO NRC for assurino consistency ano tne Support: All offices intecration of cuidance. i.e., the errort is currently tracmentea. Emergency planning cuts across several NRC office lines during the process of generating guidance to licensees and others. However, there are no effective NRC-wide procedures in place or crganizational arrangements established to ensure that adequate and clear guidance results. This lack is particularly 7;- important in view'ofJhe many interfaces involved, including the licensee, State, local, and other Federal. agencies. Currently, several organizations within the NRC can and do issue guidance to licensees without the recuired knowledge of or concurrence by all other interested organizations before the fact. This includes NRR, NMSS, SD, and IE. Also, SP does the same for other than licensee organizations / agencies. Althcugh informal internal coordination among interested parties is practiced, it is by no means certain that all coordination that is needed is perfonned. Since seme of the ccordination is _ verbal, it is not easy to observe or reconstruct. 'B NRC Incident Resconse Program ~ Resolution: Short and long term neeos exoansion anc rurtner Lead: IE deveicoment. Support: NRR/NMSS/SP Section 0502-01, Coverage, states " Guidance required for national level emergency planning is not currently included in this chapter. With modification, 1071 292
,=r.g=.. the scope of the incident' response program can be broadened to include such events. " Such a modification is in order to make Chapter 0502 responsive to the post TMI environment and current NRC needs. In addition to' the above,' the inccmplete or delinquent parts of the NRC Incident Response Program should be provided. Not al1 procedures or data required have been supplied to date. 2 The licensee's clannino is Resolutic;: Short and long term baseo on acc1 cents of Lead: NRR/NMSS severity uo to ano includina Support: IE/SP/SD tne most serious oesign basis acc1 cents. Prior to TMI there was no explicit ecognition given to Class 9 accidents in the emergency planning process. TMI highlighted the question whether NRC should require emergency planning for Class 9 accidents. .:.=. =$Ib B The NRC resconsibilities. Resolution: Long term ~- delineated ~1n FRPPNE"have Lead: SP 3at oeen 1moiementec witnin Support-MRR/NMSS/IE/EDO the NRC. The Federal Response Plan for Peacetime Nuclear Energencies (FRPPNE)* identifies ~ the NRC as an Operational Response Planning Agency (ORPA) for tw'c catecaries of peacetime nuclear amergencies (PNE's) fran a ecmprehensive set of ferr catecaries of such emergencies. The ORPA responsibilities are to: (a) Determine the complete list of Federal and private supporting agencies and enlist their assistance. (b) Provide guidance, peculiar to the operational response planning agency (s) " type of PNE, for use by appropriate Federal support agencies. This cuidance should include assumotions and casualty and crecerty damace estimates that can be used as a standard data base for olannine. (c) Ensure that all functions essential to an effective response are included in the p.lanning for which the operational planning agency has the lead responsibility. These functions should include the
- See footnote on page 3.
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c8-techri.a .nes, required to assess, counteract, and control the radiological effects; the humanitarian ones, desigr;ed to minimize the impact on individuals; and the recovery ones, directed at restoring essential services to the affected area. NOTE: The functions includC in the above responsibilities include but are not limited to these: notification, cc::munication, evaluation. decision making, public information, law enforcenent, health and safety services, survival operations, international relations, and short term recovery operations. B The need for research or studies in Resciction: Short ter n tne emercency rescanse area nas not Lead: SP been comorehensively evaluated. Support: All staff offices NRC has sponsored a modest research/ study program in areas related to emergency planning and response. However, it should be determined if additional efforts are needed to validate our current planning and response concepts. B NRC has no control over other Resoluticn: Long term acency resources asslaneo to the Lead: SP Reclonal Acylsory Committees Support: IE '(RAC's The rt.;ources that other agencies supply to the 10 RAC's are deter nined by them and are offered on a limited time basis. Therefore, the scheduling and coordination that ensues is captive to a v'oluntary v 3 uncertain set of circe:r. tances that can produce variable results af2 -:ing quality of output. It is not clear that NRC's requirements will be met t.nder this voluntary arrangement. Similarly, NRC's own representation to the RAC's is extremely limited and on an additional duty basis. C_ - Reculations and Cufdance Problems exist in the areas of both regulations and regulatory guidance. Regulations are incomplete in some parts, and guidance is inadequate in terms of the lack of acceptar.;e criteria and the frequent use of crther -1., 10 /1 2 M =-
than Regulatory Guides as a source of licensee guidance. C NRC emercency olannina itesoluticr. Short and long te.2 culcance neeas 1morovement. Lead (Licensee):.NRR/NMSS - Support (Licensee): All staff offices Lead (State /lcul): 59 Support (State / ocal): All staff office (t ) It does not necessarily contain specific NRC acceatance criteria; ~ (b) it is not restricted to that which is needed for implementing the ' NRC position as defined in Regulatory Guides (e.g., branch technical positions, talletins, circulars, generic letters, etc.). Enile acceptance criteria can be developed for' strictly licensee functions, there is a question whether the tem " acceptance criteria" is applicable to the offsite elements of the emergency plan. 7..=., Because of the uncertainties rooted in the lack of criteria for an emergency plan, most of the offrite elenents of a licensee's plan are generated in a quasi-regulatory atmosphere. The draft of revised Regulatory Guide 1.89 on qualification of equipnent to radiation source tems should be issued. C Reculations have voids or Resolution: Long term inconsistencies related to lead: SD emercency olann1nc. Scpport: NRR/NMSS/IE/SP Part SO, Appendix E, requirements have not been applied to research reactors licensed prior to its. adoption. Part 30 does not require energency plans or procedures. t Par' ?O does not regire emergency" plans. Part 70 does not require all licensees to have approved emergency response plans. There is no requirement that emergency plans be kept up to date. - =.. - 1071 ^$5
..= .Es, C P otective Action G'uides have Resolution: Short tem ~ not been oremulaated as Lead: SP official receral quicance. Support: N/A If Protective Action Guides (PAG's) were premulgated as official guidance from the Federal government, it is likely that PAG's would be more unifomly adopted and implemented by all parties involved. ~ D_ Licensino Four problem areas exist in licensing to meet radi,ological energencies. Three of these relate principally to the capabilities and degree of cerrmitment of resources external to the site for use during emergencies. The fcurth addresses the problem of NRC interaction with the public, during the licensing process, withcut a well-def.ned generic basis for . response. 0 Durino the licensino crocess. NRC Resolution: Short tem .. GL coes not fuiiv assess actual Lead: NRR/NMSS r . offsite caoability but limits Support: IE/SP/EDO examination to :ne cieoces of resources. The licensing of facifities to assure an adequate response to nuclear emercencies may include field trips by NRR/NMSS to discuss the capabilities available offsite in addition to IE's perspective of such capabilities. These may take the fom of ascessments or evaluations of these resources, at least in the numbers, types, tcaining curricula, etc., but normally do not include a comprehensive assessment of resources likely to be brought to bear. As such, the actual capability available is not known in very great detail either before or after a license is_ granted. 0 The NRC " concurrence" related to Resolution: Short term State olans is not directly Lead: SP relateo to the 11censino crocess. Support: NRR/NMSS Present concurrence in State plans by NRC is neither necessary nor sufficient for the licensing decision-making process. 10/1 )6 '~ ~
P00ROR K -y D The assistance to States is not Resolution: Long term farmally.coupiec.to tne Lead: SP licensina crocess. Support: NRC/NMSS The planning assistance that NRC provides to States, though small cur ently, is not necessarily targeted to support NRC requirements as articulated via the licensee's emergency response plan approved by the NRC. Though the resources may be applied to desired areas, there is presently no way to assure that this occurs. D-4 Because of the lack of a ceneric Resolution: Long term treat =ent of emercency olanninT Lead: SD 1ssues in cuolic near1nos the Support: NRR/hESS same contentions receatedly occur in cuoiic croceacinas anc oiace an uncue burden on the staff. Possibly because of a lack of earlier research in the emergency planning and response area or for other reasons, a generic focus of the issmes for use in rulemaking proceedings does not exist. Because of this lack of focus, the y staff finds itself golng over the same items time after time, which is wasteful of scarce resources as well as distracting to the long-term effort. Imolementation E_ This area held che most problems of all, a total of eight-They cover the range from interagency coordination to the pre-positioning and t.aining of NRC resources. Other problem topics include facility and equipment support and timely notification of NRC that an emergency situation exists or is developing. ~ E Insufficient NRC attention has Resolution: Short and long ter n been c1ven to coorcinatino tne Lead (FRPPNE): SP Federal rescanse affectino Support: IE 11censec faciilties. Lead (IRAP): IE Support: NRE/NMSS/SP Prior to EiI, the resources assigned to the task of integrating the NRC into a national emergency preparedness program were limited, and icw in agency priority. That allocation of low agency priority (which is not unique to NRC) 1071 2,7
... =_ Dn0D nDie,m til c =._ - 1UUn UnlU JR is reflected in the fact'that the entire program has remained voluntary, and, after years of planning, the.FRPPNE is jocularly referred to as a " plan to plan." r E Licensino and insoection resources Resolution: Short and long term need excansion to cetter 1moiement Lead: NRR/NMSS/IE their emercency clannina efforts. Support: N/A Inspection and licensing efferts related to emergency planning are not in all cases closely integrated,.. The neces,sary improvements in implementation will require increased resources. E The majority of ooeratino facilities Resolution: Short and lcog term nave not oeen evaiuatec acainst tne Lead: NRR/NMSS staff's current criteria for Support: IE/SP emercency olannino. Sufficient resources are not available to review emergency plans of eristing reactor licensees to bring them into conformance with present emergency planning criteria. 35 ~ ~ ~..lf ~ E The incident resoonse criteria for Resolution: Short term timely notification of the NRC Lead: IE/SD ~ neec to oe clontenec. Support: NRR/NMSS/SP Scme basic development of methods for_ triggering licensee notification procedures and of ensuring NRC recognition of the significance of infor nation passed is required. Setting of criteria for notification and predeter:xined action is a delicate process of balancing the expense of notification / shutdown / response to some nonemergency against the need to ensure early detection of developing emergencies. E An oroanized " facility class Resolution: Short term oriented" NRC resconse cacability Lead: IE nas not oeen runiy estaoil.snee. Support: NRR/NMSS/EDO Based on the NRC role defined by the resolution of problem topic A-5, an efficient and timely response capability must then be instituted in or 'er to cope with the evolution of any futui e emergency situation. Response shx3uld 1071 298 i
orient on types, or clas'ses, of facilities so that expertise can be brought to bear quickly and effectively. Such support will be needed both in the field and at NRC headquarters. Therefore, the variables that constitute this capability must be defined, including the data base and comnunications to make the rapid assessment and response required. ~ E There is'a need durina an actual Resolution: Short term emeroency for near-to-the-site Lead: IE facility-to nouse tne multi-Support: NRR/NMSS/SP acency coordination and resconse Resolution: Long tenn succort activity. Lead: EDO Support: NMSS/NRR/IE/SP For sustained operations of a renote NRC respense team, efficiency of the participants, including the licensee, will be hampered unduly unless prov.isions are made to obtain, on a timely basis, offsite but nearby work space for NRC personnel and others. This includes both coordination and support activities. Floor space and support equipment need to be defined and arrangements made, including ccmu.unications terminals and storage for data brought with tIDeam or accumulated during the emergency. S' ort and long term E-7 Need exists for exoanded NRC Resolution: n monitorino cacability. Lead: NRR/NMSS/IE Support: Sp Although the level of monitoring capability necessary to ensure adequate performance of an NRC response team is not currently defined, the analysis of TMI experience, coupled with a better definition of NRC's role, should provide a sufficient base for estimating technical requirements. E Procedures for dissemination of Resolution: Short term puolic information are not Lead: EDO adecuate. Support: IE An adequate emergency response plan must include an effective system for infonning the public, for updating the information as new developments occur,
- -~
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.j.=- m. and for retracting,information when it is found to be in error. Mistaken or false opinions that emanate frem an emergency control center can cause damage to the public in excess of the severity of the emergency in progress. For this reason, early identification of infomation sources, concurrence in factual infomation released, and frequent updating of public information should be formalized in the planning process. F, - Testino and' Verification of Cacability Three problem topics were identified.that affect NRC's ability to assess how good the emergency response capabilities are or are likely to be when called 'on. These cover the range of response capabilities from NRC through the licensee to and including State and local resources. ~ F There has never been an NRC-wide audit Resolution: Short tem or tne emercency rescanse runction. Lead: EDO Support: N/A }.59 Although NRC has an gernal audit program, it has not applied a similar ~~ mechanism to itself f,or the emergency planning and response function. F Evaluation criteria for drills / Resolution: Short and long tem exercises are not cerineo. Lead: NRR/NMSS Support: IE/SP/SD Although a vt.rying degree of evaluation or assessment is associated ~with the licensing process, NRC does not systematically evaluate the ongoing capability for emergency response, particularly for offsite non-licersee rescurces. Evaluation criteria for this purpose exist only for the RAC's, although IE does annually verify that arrangements are still in place at power reactors and some other facilities. This does not, however, ensure their adequacy in tems of likely perfomance but is limited to confidence that they will respond. F There is no effective NRC Resolution: Short and long tem mecnanism for continued Lead: SP evaluation of tne trainino Support: IE and oualification of key State anc local emercency resconsa cersonnel. . = 1071 300
' _==_ =- 1 Even if the needed evaluation criteria (F-2) were developed, NRC would still require a program of continuing evaluation to ensure the response agencies continued to be qualified and capable of performing their assigned e mission. During 1975-1979, four independent reviews of NRC's energency response program each stressed the need for utilities and State and local emergency planning officials to realize the importance of trained radiological specialists being involved in the plans and their operations. In each of these critical discussions the moral responsibility of the NRC to assure this provision was stressed. Any mechanism developM by NRC to address this problem topic should clearly give priority to the training, continuing evaluation of capability, and necessary retraining of this requisite cadre of radiological specialists. =a =- 1071 331 O
. E* - ~ NRC ACTION PLAN FOR EMERGENCY PREPAREDNESS The NRC Action Plan for Emergency Preparedness comprises six individual plans that'were coordinated by means of the Task Force. One plan,, prepared by RES and designated "0RG," considers overall (agency-wide) problems and 7 addresses the attributes of a coordinated NRC-wide emergency preparedness arcanization. The other five plans address problems specific to individual-h vw c.u offices and were prepared by those offices. The six plans were Teach prepared to correspond to'the following format: I. Introduction II. Summary and Conclusions ~- III. Responsibilities Relative to Emergency Preparedness ~ IV. Current Program and Capabilities V. Requirements and Seeds = sis ~ VI. -Action Plan for Named Of fice The plans are presehted below under the following tabs: ORG,ilRR, NMSS, IE, SP, and 50. A summary of proposed actions follows. -^ Os G G 1071 302 M
2 ~ g Summary of Procosed' Actions in Chronological Seouence v ae -d?Nce o Soecific Task
- p g August 1979 (IE)
B-2 Upgrade NRC Operations Center o as .f ties. August 1979 (IE) B-2 Improve heating, ventilating, and air ccaditioning for NRC Operations Center. A-2 Augus t 1979 . (IE) & E-1 Meet with Forest Service concerning support to IRAP. A-2 Septerter 1979 (IE) & E-l Meet with IRAF signatory agencies to identify problems regarding TMI-2. October 1979 (IE) B-2 Revise NRC Manual Chapter 0502 (without explicit definition of NRC role,in emer5cacy response). Define enb ronmental radiation r:cnitoring capability. October 1979 (IE) E-7
- -tober 1979 (IE)
E-2 Identify categories of material licensees . emergency response plans should be require,for which d. Octcber 1979 (GG) Rule Publish for coment proposed rule for which "early notic was published on July 17, 1979. ) December 1979 .(IE) B-2 Upgrade furniture and audiovisual support equipment in ((= NRC Operations Center. December 1979 (IE) B,2 Upgrade NRC Operations Center support staff'. Decemoer 1979 (NMSS) B-3 Prepare criteria for determination of need for and scope of fuel-cycle and byprocuct material licensee emergency pl ans. January 1980 (NRR) B-3 Complete the design review and prepare revised prt-cedures for post-accident sampling. January 1980 (NRR) B-3 Requi re improved in-pl ant iodine instrumentati on. Januarf 1980 (IE) E-7 Order radiation monitoring equipment to establish an NRC environmental monitoring capability. January 1980 (0RG) Rule Publish final rule for which "early notice" was published on July 17, 1979. 1071 ~303 Place TLD around operating power reactors. January 1980 (IE) E-7 s January 1980 (SP) A-2 Stake out prominent role for NRC in development of the & E-I National Contingency Plan. A-2 (SP) & :-l Complete NRC agency plan for responding to nuclear accid March 1980 March 1980 (SP) A-2 Include appropriate language in NRC regulations related & E-1 to State and local radiciogical emergency response plans on coordination among the various levels of government botn in tne planning and response periods.
1 nqM W h. tompletion Prob. g1 .d Date. ' Office - No. Soecific Task l -March 1980 (SP) 8-4' ' Complete NRC agency response plan for peacetime nuclear emergencies taking into account responsi-bilitie,s outlined in FRPPNE. M' arch 1980 (NMSS) E' 2 Es'tablish Environmental Radiation and Emergency Support Sections.and coordinate its activity.with IE and SP activities. March 1980 (NMSS) Prepare value-inuact analysis for extending emergency planning requirement 5 to additional fuel-cycle and byproduct material licensees. April 1980 (IE) E4' Make initial ec,llection of NRC's 'TLDs. April 1980 (IE) E-7 Develop supplemental budget for environmental mo r.i to ri ng eq ui pmen t no t al ready o n orde r. April 1980 (IE) E-7 Procure equipment / data links for NRC monitoring of operational parameters at nuclear plants. April 1980 (SP) A-2 Work with FEM to seek a censensus among States & E-1 concerning the preper roles for State and local governments in radiological emerg'ency response. (SP) 4 B-4 Work with FEMA in the development of the President's A-T April 1980 . " National Contingency Plan." April 1980 (IE) E-2 Revise IE Manual Procedures. June 1980 (IE) A-5 Define NRC's role in emergency response. June 1980 (SP) C-1 Carry over into regulations the acceptance c-iteria concept for State and local government plans. June 1980 (SP) C-1 Work wi th FEMA to develop improved handbcok of guidance for Federal agency assistance activities with the States June 1980 (SP) C-1 Work with FEM to prepare an improved emergency plannin guidance document for the States and local governments. June 1980 (SP) 0-2 Push for concurrences in plans in States that have operating nuclear power plan's using existing guidance and precedures. June 1980 (SP) .0-2 Begin codifying existing guidance to State and local agencies into regulations. June 1980 (SP) D-3 Work wita FEMA to establish some Federal mechanism to certify emergency planning and response personnel of S' ate and local agencies. 1071 304
~ is = . Completion Prob. -4 rgj Date~ Office No. Soecific Task . dune 1980 (SP) .B-6. Have FEMA re-establish the Regional Advisory Committees on a formal basis for all-hazards emergency planning, with NRC to be' a member Federal Agency. July 1980 (NRR) E-6' Designate location and alternate location for Emergency Operations Center for use of Federal, State, and local officials; provide corrmunications between Emergency Operations Center.and plant. July 1980 (NRR) E-7' ' Improve off-si te monitoring capability. July 1980, (SP). Assum adequacy of State / local plans against , current criteria. July 1980 (NRR) D-I. Conduct test exercise of power reactor licensee emergency plans. July 1980 (Sp), Conduct test exercise of State emergen y plans. July 1980 (IE) E-2 Procure equipment / data links for plant discharge moni to rs. kkhJuly1980 (IE) .E-2 Develop procedures for int.pecting byproduct material licensee emergency plans. July 1980 (NMSS) E-J Draft Reg Guide, Acceptance Criteria, and Standard Format and Content documents for fusi-cycle and by. product material licensee emergency p1ans. July 1980 (NRR) C-1 Upgrade emergency plans for power reactors to meet & E-2 Reg Guide i.101 with special attention to action level criteria based on plant parameters. September 1980 (SD) 0-4 Res01ve Critical Mass Petition for Rulemaking. September 1980 (50) D-4 Revise Reg Guides 1.101, 3.42, and 2.6. September 1980 (SP) B-5 Prepam research study proposals based on analysis of studies now being done. September 1980 (SP) F-3 Work with FEMA to establish retraining programs for State and local agency personnel. October 1980 (IE) E-2 Commence inspection of byproduct material licensee emergency plans. 1 L)71 ?.05 Decemoer 1980 (NMSS) C-1 Pursue rulemaking proceedings to require emergency plans for fuel-cycle and byproduct material licensees not now required to have these plans. December 1980 (Sp) A-3 With FEMA, develop proposed rulemaking or iecislation to resolve the problem of funding for State and local agencies to support radiological emergency response planninc and preparedness.
N Complet, ion Prob. 5E=' Date Office-No. Snecific Task . Decenter 1980 (Sp) F:3' Work with FEMA and other Federal agencies to establish additional required training programs for State and local agency personnel. ^ Uanuary 1981 (SP) Assure adequac.y of State / local plans against upgraded cri teria. January 1981 (NRR/SP) Canduct joint test exercise of Federal / State / local and power reactor licensee emergency plans for new 0lis. January 1981 (NRR) E-7 Require high-range radioactivity monitors at nuclear & B-3 power plants. January 1981 (NRR) B-2 Upgrade Emergency Operations Center in con, junction with in-plant technical support center. July 1981 (NMSS) C Update or supplement Reg Gui.de 3.42, Rev.1, to cover Part 30 and Part 40 licensees. July 1981 (NMSS) E-3 Issue final (effective) Reg Guides, Acceptance Criteria and Standard Format and Content documents for fuel- --Q cycle and byproduct material licensee emergency plans. September 1981 (SD) ' D-4 Develop emergency planning regulations for research reactors. December 1981 (NMSS) C-1 Establish criteria for review and inspection of by-product and source material licensee's emergency plans. September 1984 (NRP/SP) F.2 Conduct joint test exercise of Federal / State / local and power reactor licensee eraer2ency plans for all cperating plants. 1071 306 -}}