ML19250C388
| ML19250C388 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1979 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Fowler S NEBRASKA, STATE OF |
| Shared Package | |
| ML19250C389 | List: |
| References | |
| NUDOCS 7911230334 | |
| Download: ML19250C388 (4) | |
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'NOV 7 1979 The Honorable Steve Fowler Nebraska Senate District No. 27 1st Floor - Room 1110 Lincoln, Nebraska
Dear Mr. Fowler:
This is in response to your letter of October 2,1979, to Chairman Joseph Hendrie.
The numbered responses below correspond to your numbered questions.
1.
NRC and other participating Federal agencies have provided guidance to the States on radiological emergency planning.
The principal document used has been NUREG-75/lll, " Guide and Checklist for Development and Evaluation of State and Local Government Radiological Emergency Response Plans in Support of Fixed Nuclear Facilities." NUREG-75/lli does not address the matter of providing education to residents near a nuclear facility. The Nebraska plan was reviewed against the planning and guidance elements set forth in NUREG-75/lll, particularly those identi-fied as critical in Supplement No. 1.
The Federal agencies reviewing Nebraska's plan found that it addresses the elements in NUREG-75/lll to the extent they felt they could concur in the plan.
NRC has noted the GA0 recommendations and has the following position on this issue, as set forth in a June 26, 1979 letter to GA0 from Chairman Hendrie.
The experience of TMI shows that the present procedures for in-forming the potentially affected population : ear nuclear power plants should be re-examined.
Consequently, we are evaluating all our procedures in the communications area. We have to deter-mine what infonnation - general and site specific -- should be given to the public prior to. an emergency to assure effective response if a radiological emergency occurs.
In addition, we must clarify procedures for communicating with the public during a radiological emergency: who should provide the information, what information should be provided, and what modes of communi-cations should be used.
The Commission will take the necessary actions to implement the GA0 recommendaiton in connection with its ongoing assessment of regulatory requirements and the ade-quacy of State and local plans in emergency planning and pre-paredness.
The Commission makes no comment on the GA0 recommendation to D0D and DOE. However, we will provide appropriate support in those States a-d local areas where joint planning is necessary for emergencies from both licensed and government nuclear facilities.
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t Steve Fowler NRC's evaluations of its procedures relatug to emergency planning and other aspects related to the accident at Three Mile Island have not been completed.
The NRC Task Force investigating this accident, as well as the President's Comission (Kemeny Commission) and other investigating bodies, are expected to issue their findings and re-comendations shortly. They will be addressing emergency planning and preparedness specifically, and their positions will be carefully considered in developing any revisions to NRC procedures.
In the meantime, NRC and the other assisting Federal agencies have continued their reviews of State radiological emergency response plans against the current guidance.
It is useful to continue these reviews and the development of emergency plans where they do not already exist-in full conformity with this guidance.
As further guidance is developed, the emergency plans can be upgraded to meet new or expanded criteria.
This is consistent with the view of the U.S. Senate in its passage of S.562 on July 17, 1979 with a vote of 97 to 1 (not acted upon by the U.S. House of Represcntatives).
S.562 proposes, in part, that NRC review of Statt plans continue with no change in criteria while there is an ongoing development of more fonnal and improved criteria in specific regulatory requirements.
2.
The Nebraska Plan, which includes the local Washington County Plan, does have information on notification of the public.
There could be some improvement in these documents by better indexing and, perhaps, by a use of a summary section which highlights major points.
The following points appear to be relevant to decisions on public notification.
a.
The Governor's designated representative is the Nebraska Adjutant General and State Civil Defense Director.
Reference page 9 of Nebraska RERP.
b.
Decision concerning method of notification to the public is the responsibility of the Governor or his representative.
Reference page B-2 of Nebraska RERP.
c.
Washington County Plan, page A-3, specifies that the decision to evacuate or shelter under the situation where the plant advised this action should be taken immediately, would be the responsibility of the County Board Chairman, on the advice provided by his County Civil Defense Director.
The implementation of that decision is the responsibility of the Sheri f f.
d.
The method that is used, whether it be for immediate action or under a situation of an escalating emergency, would be determined based on consideration of many factors, including time of day, weather conditions, and immediacy of the action, as advised by the plant or the State Department of Health.
The point to be made is that no one method can be chosen as best for all emergency situations.
It could be that a combination of techniques to warn the people would be used. That is, 1387 181
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a,
StevieFowler alternatives are clearly identified in both the State Radiological Emergency Response Plan and the Washington County Plan, namely sirens, telephone numbers for news media, law enforcement systems, the National Warning System (NAWAS) and the Emergency Broadcast System. The actual and specific time required for each alternative method of providing warning to the public can only be determined through an actual test of the system but can certainly be estimated very accurately based on routine natural disaster warnings through the NOAA weather system, NAWAS and others.
3.
The Nebraska Plan, like any other State plan, does not impose requirements upon the facility operator as to how the 1acility is constructed or operated.
The NRC is the agency with responsibility and jurisdiction over design, construction and operation of licensed nuclear facilities.
NRC fully supports the view that radiation monitors must provide accurate and timely information.
This issue is specifically addressed in NRC's TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations, NUREG-0578, July 1979 (copy enclosed, see page A-36). On September 13, 1979 NRC wrote to all operating nuclear power plants to infom them of actions and schedules to be met resulting from NRC staff reviews of the TMI-2 accident (copy enclosed). This letter specifically addressed the NUREG-0578 recommendation relating to radiation monitors.
A schedule for upgrading of monitoring instruments was set for meeting the new requirements by January 1, 1980.
4.
NRC concurrence does indicate a belief that there is a local capacity to shelter people in an emergency.
The Nebraska Plan is slightly misleading in its discussion of availability of public shelters.
If an accident occurred where sheltering were indicated as appropriate, those persons already in their own residences or offices or factories or other facilities would be asked to remain in place and receive the sheltering benefit from the structures they were occupying.
Public shelters would mainly be used for unsheltered persons who were in close proximity to those shelters.
However, nearly any building would provide some protection from an airborne plume of radioactive material from a reactor accident.
Use of a specifically established fallout shelter or other public shelter would not be necessary.
For those persons for whom no appropriate shelter was immediately available and who would need to be transported elsewhere, they would nomally be transported entirely out of the area of exposure to the radioactive plume, rather than to a shelter.
5.
NRC concurrence does indicate a belief that Nebraska State and local agencies have a reasonable capacity to effect such evacuation of people as may be needed in the event of a nuclear plant emergency.
The statement that " Risk population is based on resident distribution and does not consider visitor and transient sectors," applies only to reception areas.
Reference page D-7 of the Nebraska RERP. The Plan does recognize the transient population as evidenced by reference to the DeSoto Wildlife Refuge and the Indian Caves State Park (pages D-3 and D-5 of the Nebraska RERP, respectively).
Additional and more detailed evacuation planning is found in the radiologiu:1 emergency response plan for Washington County, Nebraska for tha Fort Calhoun i3R7 1b2 a
Steve Fowler plant and will be included in the plan for Nemaha County for the Cooper plant.
6.
We agree that exercises to test the adequate implementation of the radiological. emergency response plan should be comprehensive and should test the capability of the State and local governments to take protective measures in the environs of the nuclear plant.
While the drill at Fort Calhoun was limited in scope and may not have fully tested the capability for sheltering or evacuation, the NRC currently has under development a nuclear power plant accident scenerio for use in testing this aspect of State and local emergency response plans.
This scenerio will postulate a release of radioactivity to the envi-ronment such that offsite protective measures will have to be consi-dered by the emergency response personnel.
We intend to begin using this scenerio shortly although Nebraska will not be affected until its next annual exercise.
Concerning the use of emergency planning zones for identifying the area at risk, the Commission has recently approved the conceot of the 10-mile emergency planning zone for the inhalation pathway for taking protective actions such as evacuation or shelter. A copy of a Fed-eral Register notice and the document NUREG-0396 explaining this pol-icy is enclosed. As you will note, this concept will be incorporated into the new emergency planning regulations which are currently being draf ted and will be required to be implemented over the next several months to a year.
I hope these responses satisfactorily answer your concerns.
If you would like to discuss them further, however, please call liarold Collins, Assistant Direc-tor for Emergency Preparedness in our Office of State Programs at 301/492-7210.
Sincerely, lf. /]nn Lee V. Gossick Executive Director for Operations Enclosures as stated.
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