ML19250C517
| ML19250C517 | |
| Person / Time | |
|---|---|
| Issue date: | 07/19/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Collins H, Grimes B Office of Nuclear Reactor Regulation, NRC OFFICE OF STATE PROGRAMS (OSP) |
| Shared Package | |
| ML19250C514 | List: |
| References | |
| NUDOCS 7911270141 | |
| Download: ML19250C517 (1) | |
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NUCLEAR REGULATORY COMMISSION UNITED STATES 7 l !
o WASHINGTON, D. C. 20555
% h JUL19 1979 MEMORANDUM FOR:
Har:1d E. Collins, SP Brian K. Grimes, NRR Co-Chairmen of the NRC/ EPA Task Force on Emergency Planning FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
COMMISSION PAPER CONCERNING NRC/ EPA TASK FORCE REPORT NRR concurs in the Policy Statement being issued. The enclosed memorandum from Daniel Muller, Acting Director, Division of Site Safety and Enviromental Analysis, NRR, contains comments on the proposed Commission Paper which should be included as part of Enclosure 4 thereof.
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Harold R. Denton, Director Office of Nuclear Reactor Regulation Enclosure.: As stated 1395 171 mN a
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0, UNITED STATES y
g NUCLEAR REGULATORY COMMISSION 3
.: p WASHINGTON, D. C. 20555 JUL 191979 MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:
Daniel R. Muller, Acting Director Division of Site Safety and Environmental Analysis, NRR
SUBJECT:
COMMISSION PAPER CONCERNING NRC/ EPA TASK FORCE REPORT This Division does not concur in the proposed Commission Policy Paper, dated July 13, 1979. Our coments are as follows:
1.
The proposed policy statement does not reflect changes and clarification of the Task Force Report recomendations which are clearly needed in the light of the public coments received.
2.
No value-_ impact analysis has been provided to guide the Comissioners' decision on whether or not to approve publication of the propo:ed policy statement. Public coments clearly reflect substantial uncertainty as to the impact of the guidance if adopted.
3.
The proposed policy statement, as well as the Task Force Report, fail to come to grips with the evacuation issue.
4.
The proposed policy statement fails to take specific cognizance of the Task Force Report's observations on the relationships between emergency planning policy and siting policy.
5.
As an alternative to the proposed policy paper, we recommend that it be changed to an information paper and that the recommendations of the Task Force be made jointly to the existing NRC Task Forces on Emergency Planning (T. J. Carter) and on Siting Policy ( D. R.
Muller).
kSM Daniel R. Muller, Acting Director Division of Site Safety and Environmental Analysis
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J PLANNING BASIS FOR EMERGENCY RESPONSES TO NUCLEAR POWER REACTOR ACCIDENTS AGENCY: Nuclear Regulatory Comission ACTION: NRC Policy Statement Purpose This is a statement of policy with regard to an Environmental Protection Agency (EPA) and Nuclear Regulatory Comission (NRC) task force report on guidance for use in state and local radiological emergency response plans at nuclear power plants.
Backaround The NRC received a request from the Conference of Radiation Control Program Directors, an organization of State officials, to "make a determinatio" of the most severe accident basis for which radiological emergency response plans should be developed by offsite agencies."
In response,an EPA and NRC task force was established which prepared a report entitled " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," NUREG-0396, EPA 520/1-78-016, dated December 1978. Single copies of the report can be obtained by writing to the Director, Division of Technical Information and Document Control, Nuclear Regulatory Comission, Washington, D.C. 20555.
The task force report was published for public coment in the Federal Register on December 15, 1978 and the coment period was extended to May 15, 1979 to allow additional coments resulting from the accident at Three Mile Island. A synopsis of the consideration of these comments is avai DUPLICATE DOCUMENT for Emergency Preparedness, Office of 5 Entire document previously entered into system under:
Comission, Washington, D.C. 20555.
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Anust 21,1979 SECY-79-499 COMMISSIONER ACTION For:
The Comissioners From:
Lee V. Gossick Executive Director for Operations
Subject:
REPORT OF TASK FORCE ON EMERGENCY PLANNING Purcose:
To obtain Comission action on the recomendations of the Task Force on Emergency Planning, d
Ofscussion:
The Task Force on Emergency Planning was established 3
in June 1979 to identify weaknesses in NRC's g
emergency preparedness process and to outline w
an approach for improving NRC's overall emergency preparedness activities. The Task Force Report, submitted on August 9,1979, is provided as Enc 1csure 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 proposed rulemaking. 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 l 3()b l / /}
.. 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 problem topics is provided as.
MpA will track progress on the tasks through the Decision Unit Tracking System.
The office tasks involve short-term actions, some of wr.ich are already underway, and long-term tasks that form 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 emergency 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 Commission's review of NRC's FY 1980 supplemental and FY 1981 budget.
Consequently resource requircments 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 example:
1395 175
. 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 fomed and assigned the lead for emergency preparedness?
3.
Should a new position be created for a
" Technical 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.
L// Lee V. Gossick Executive Director for Operations 3
Enclosures:
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Sumary of Fi l' 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 M95 176
> 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 September 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 sFw;1d be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners Commission Staff Offices Exec. Dir. for Opers.
ACRS Secretariat i395 1/7
Vaif Sy1V'n 26; n
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ENCLOSURE 1 1395 1/8
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MPA Sumary of Reoort of Task Force on Emergency Planning In June 1979, the EDO established the Task Force on Emerg cy Planning in response to the TMI-2 accident, recommendations from a GA0 report, and various petitions for rulemaking from interest groups. 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 planning activities.
The Task Force identified fourteen issues that were published for comment on July 17,1979 f r. the Federal Register in an advance notice of proposed rulemaking.
After analysis of public comments, 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 local plans be required for a reactor to operate; what should be the objectives of emergency planning; how can financial assistance be provided 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 should 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 pla1ning problems identified by the Task Force.
The Task Force identified 30 problems in examining NRC's current process. These problems lie in six aieas 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 (F) emergency response testing and verification capability.
Individual offices used these prcblems as a basis for laying out specific remedial tasks.
The short term tasks ire expected to be completed by January 1,1980 and long-term ones by 1984.
Resources The Task Force identifies the need for 44 additional people.
These people are needed for the following activities:
O" Areas Around Nuclear Facilities Should be Better Prepared for Radiological Emergencies," March 1979.
1395 179
- (cont.) People Office Activity 8
NRR Evaluation / Instruction Teams 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 coordinaticn.
2 SD Restructuring of regulations The Task Force Report recommends:
1.
Give prompt high-level management 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 January 15, 1980. The life of the comittee should be for 2 years.
3.
Create a position,. 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, comprehensivg 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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ENCLOSURE 2
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14 ISSUES FOR CONSIDERATION IN RULEMAKING (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 continued 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 9.
Incident / emergency notification criteria 10.
State / local / licensee influence on federal 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 39.fh
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30 Problems of Current NRC Process Identifiec by tne Task Force on emergency Planning Lead Office A.
Responsibilitv/ Authority 1.
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.
Trinsportation EP inadequate NMSS 5.
NRC role in EP inadequately defined IE 6.
Licensee responsibility for offsite EP exceeds NRR/NMSS authority 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 :ontrol over resources of other agencies SP assigned to RfL C.
Regulations and Guidance 1.
NRC EP guidance non-specific NRR/NMSS/SP 2.
EP regulations and their application inconsistent SD and incomolete 3.
Protective Action Guides not uniformly adapted or SP implemented
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Licensing 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 integratec 3.
Upgrade of cperating facility plans to current criteria NRR/NMSS 4.
Incident response criteria for notifying NRC too loose IE/SD 5.
NRC response capability not fully established IE EP = emergency preparedness i 2, o e ju9 9,;
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Lead Office E.
Imolementation, cont'd.
e 6.
Near-to-site facility for response persennel non-IE/E00 existent 7.
NRC monitoring capability inadequate NRR/NMSS/IE 8.
Procedures for informing public of accident ED0/PA status inadequate F.
Testino and Verification Capability 1.
NRC-wide audit of EP non-existent E00 2.
Criteria for drills undefined NRR/NMSS/SP 3.
Continued evaluation of training and qualification SP of State and local personnel non-existent i 395 i85 0
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Office Tasks Sorted by Problem A.
Responsibility / Authority Completion Problem A-1 FRPPNE SHOULD BE CLARIFIED WITH RESPECT TO NRC'S STATUTORY RESPONSIBILITIES SP Tasks a.
Query FEMA on status of FRPPNE Immediate b.
If FRPPNE still operative, review FRPPNE and Atomic Immediate 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 FRPPNE, and perhaps IRAP.
Problem A-2 FORMAL ARRANGEMENTS ARE ILL-DEFINED FOR INTER-AGENCY (FECERAL, STATE, AND LOCAL) COORDINATION.
THE PROCESS CURRENTLY IS ON A VOLUNTARY BASIS.
SP Tasks - FRPPNE a.
Outline what agencies should be involved in Federal Immediate coor *. aced radiological emergency response and how coordinaticn should take place.
Seek other agencies' agreementT' 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 i;RC 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 f;RC regulations March 1980 related to State and local radiological emergency response plans.
Meet 'ath Forest Service concerning support.
August 1979 b.
Identify problems re TMI-2; IRAP agencies and others September 1979
- meet, c.
Revise and rewrite IRAP.
Long Term
. Completion Problem A-3 THERE IS NO INTEGRATED FEDERAL MECHANISM FOR THE FUNDING OF STATE AND LOCAL AGENCIES TO SUPPORT RADIOLOGICAL EMERGENCY PREPAREDNESS
, SP Tasks a.
Complete the NRC Funding Study (Saloman Report, NUREG-Immediate 0553).
b.
Based on Saloman Report, outline options for future Immediate 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.
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.
Problem A-5 NRC HAS NOT ADEQUATELY DEFINED ITS ROLE IN EMERGENCY RESPONSE IE Tasks a.
Coordinate with NRR, NMSS, and SP on development of Short-T' ra e
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 0FFSITE 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 1930 necessary arrangements for supporting activities of State and local agencies having emergency response roles.
1395 188
3-S.
Planning Process Completion Problem B-1 FOR THE EMERGENCY PLANNING PROCESS, NO EFFECTIVE MECHANISM EXISTS WITHIN NRC FOR ASSURING CONSIS-TENCY AND THE INTEGRATION OF GUIDANCE, i.e., THE-EFFORT IS CURRENTLY FRAGMENTED EDO Tasks a.
Recognize lead offices for the following areas of res-Short Term ponsibility:
NRC commend 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 Short Term provide a focal point for staff action.
Problem B-?
NRC INCIDENT RESPONSE PROGRAM NEEDS EXPANSION AND FURTHER DEVELOPMENT.
IE Tasks a.
Upgrade Operations Center comunications.
August 1979
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air conditionii9 August 1979 c.
Revise Manual Chapter 0502 without defining NRC's role.
October 1979 d.
Upgrade Operations Center furniture.
December 1979 e.
Upgrade Operations Center audiovisual support.
December 1979 f.
Upgrade Operations Center support staff.
December 1979 g.
Incorporate appropriate national-level planning Short Tem in guidance.
h.
Increase incident response program manpower by 2 Long Term
- i. Upgrade Operations Center to handle data input (per Long Tem 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 Tem 1.
Vograde field communications.
Long Tem m.
Develop rulemaking to detemine who pays for ccmuni-Long Term cations at licensee sites.
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" Comoletion Problem B-3 THE LICENSEE'S PLANNING IS BASED ON ACCIDENTS OF i'
SEVERITY UP TO AND INCLUDING THE MOST SERIOUS OESIGN BASIS ACCIDENTS.
NRR Tasks - Reactors a.
Revise proposed changes to Appendix E to reflect NUREG-Short Term 0396 guidance; backfit Regulatory Guide 1.97 from TMI letsons 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 - Fuel-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 S-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 and for NRC.
b.
Determine what emergency preparedness studies are ongoing Immediate or ccmpleted at other Federal agencies.
c.
Seek NRC proposals for additional research studies.
Immediate IDS 190
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SP Tasks, cont'd.
d.
Prepare research study proposals identified in "c."
September 1980 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-hazards 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.
Elab3 rate in Regulatory Guide 1.101 on uniform action July 1980 level criteria.
NMSS Tasks - Fuel-cycle Facilities a.
Establish an interim position on requirements for non-Longterm 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 pi'omulgate 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.
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, Comoletion Problem C-2 REGULATIONS HAVE VOIDS OR INCONSISTENCIES RELATED TO EMERGENCY PLANNING.
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 and approval.)
b.
Evaluate the need for an " Appendix E" for Part 30 and Long Term Part 40 licensees.
r'roblem C-3 PROTECTIVE ACTION GUIDES (PAG's) HAVE NOT BEEN PROMULGATED AS OFFICIAL FEDERAL G' IDANCE.
J 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.
Licensing Problem D-1 DURING THE LICENSING PROCESS, NRC DOES NOT FULLY ASSESS ACTUAL OFFSITE CAPABILITY BUT LIMITS EXAMIN-l ATION TO THE PLEDGES OF RESOURCES.
NRR Tasks - Reactors a.
Assess offsite capabilities in licensing oracess Short Tenn AMS5 Tasks - Fuel Cvele Facilities
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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.
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Assess aid confirm the offsite capabilitin by actual Long Term c.
inspection and discussions with licensees and State and local agencies, d.
Assist all parties in developing adequate emergency Long Term plans.
Problem 0-2 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.
d.
Shift from a concurrence process to an approval June 1980 process using the new regulations.
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_7 Comoletion l Problem D-3 THE ASSISTANCE TO STATES IS NOT FORMALLY COUPLED TO THE LICENSING PROCESS.
SP Tasks The emergency preparedness assistance orocram 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 PROCEED:NGS AND PLACE AN UNDUE BURDEN ON THE STAFF.
SD 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.
Revision 2 of Guide 1.89 on qualification of equiment.
A proposed rule or policy statement on the emergency p1anning 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 FEDERAL RESPONSE AFFECTING LICENSED FACILITIES.
SP Tasks - FRPPNE Tied to other actions caes 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 lJr]r 107 7O 1 / ')
See A-1, A-2, and B-4.
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' 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-31 Short Term
-- Budget process to suoport Reg. & gu.'de Changes, offsite Long Term monitoring, information gathering NMSS Tasks -. Fuel-cycle Facilities a.
Install an Environmental Radiation and Emergency Support Fall 1979 Section (ERESS) that will guide and coordinate NMSS activities relative to emergency preparedness.
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 ( AW55),
January 1980 Develop procedures for inspecting licensees July 1980 Commence inspections.
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
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Evaluate licensee plans acainst 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 1395 194
- g-Comoletion NMSS Tasks b.
For those NMSS licensees not presently required to have approved emergency plans:
Seek short-term remadies in existino regulations and Short Term 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 Term 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 unrastricted areas Notifications of incidents Emergency plans for production and utilization facilities Emergency plans for production and utilization facil-ities Emergency plans for Part 50 and ' art 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.
! i 9.b
} ')b Comoletion Problem E-6 THERE IS A NEED DURING AN ACTUAL EMERGENCY FOR NEAR-TO-THE-SITE FACILITY TO HOUSE THE MULTI-AGENCY COORDINATION AND RESPONSE SUPPORT ACTIVITY IE Tasks a.
Integrata site support and functions with Regionai Short Term Office response b.
Identify operational and support requirements and Short Term have ADM make prearrangements to obtian. support during incidents; incorporate in Incident Response plans.
c.
Based on definition of NRC role; revise existing Long Term support capabilities.
ECO Tasks a.
Likely designate IE lead office.
Long Term b.
Define emergency preparedness responsibilities to Long Term avoid overlap; coordinate IRAP and DOE resources
'c.
Integrate drills or tests of response plans into 1.ong Term the program, d.
Explore modular concepts for facility.
Long Term e.
Give priority to radiological monitoring.
lLong Term f.
Assign NMSS and NRR responsibility for providing Long Term technical personnel and equipment for mobilization of the response teams.
Problem E-7 NEE 0 EXISTS FOR EXPANDED NRC MONITORING i
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-anique monitoring Short Tern requirements.
c.
Equip NRC response teams to assess environmental Long Term contamination resulting from unplanned releases from NMSS-licensed activities.
d.
Identify likely contaminant isotopes and levels as Lcng 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.
1395 196 Comoletion
,' IE Tasks a.
NRC offices will identify areas where expanded NRC monitoring capabilities are necessary:
Defir.e operational parameters January 1980 Define environmental monitorin capability October 1979 Define plant discharge monitoring needs January 1980 b.
Procure equipment and develop procedures for use:
Place TLO'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 19S0 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
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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 authority.
F.
Testing and Verfication Capability THERE HAS NEVER BEEN AN NRC-WIDE AUDIT OF THE Problem F-1 EMERGENCY RESPONSE FUNCTION E00 Tasks a.
Make a self-audit of the agency emergency preparedness December 1980 program.
Problem F-2 EVAL'JATION CRITERIA FOR DRILLS / EXERCISES ARE NOT DEFINED NRR Tasks - Reactors a.
Develop criteria for joint exercises.
Short Term NMSS Tasks - Fuel-cycle Facilities a.
Possible second review of post-licensing emergency Short Term plans for fuel-cycle facilities l3
' Comoletion
, NMSS Tasks (continued) b.
Review emergency plans submitted in support of Short Term renewal applications c.
Integrate renewal application criteria with devel-Long Term opment of criteria for review of new emergency plans.
d.
At five-year intervals, reevaluate emergency plans Long Term against up-to-date criteria, e.
Develop and/or adopt from NRR, criteria and 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 QUALIFICATION OF KEY STATE AND LOCAL EMERGENCY RESPONSE PERSONNEL
~ SP Tasks a.
Determine the attrition of NRC-trained emergency Immediate response personnel since March 1975.
b.
Determine training and replacement training needs of Immediate States and local governments for the next five years, c.
Establish Federal mechanism to certify emercency June 1980 planning and response personnel.
d.
Establish re-training programs.
September 1980 e.
Establish additional required training programs.
December 1980 1395 198
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ENCLOSURE 5 1395 199
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