ML19250C518
| ML19250C518 | |
| Person / Time | |
|---|---|
| Issue date: | 08/09/1979 |
| From: | Ted Carter Office of Nuclear Reactor Regulation |
| To: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19250C514 | List: |
| References | |
| NUDOCS 7911270148 | |
| Download: ML19250C518 (23) | |
Text
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DG 9 1979 L.
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MEMORANDUM FOR: Chaiman Hendrie.
Comissioner Gilinsky D"*
fP 3DrWU Cor.nissioner Kennedy AJh M]g@ "
N Cocnissioner Bradford
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I Cocnissioner Ahearne THRU:
Leo V. Gossick Executive Director for Operations I
FROM:
Thomas F. Carter, Jr., Chaiman Task Force on Emergency Planning SU3 JECT:
FINAL REPORT OF TASX FORCE ON EMERGENCY PLMNING The Task Force on Emergency Planning, which was established by the Cor: mission in its meeting of June 7,1979, was given three general responsibilities:
(1) develop for Cemission consideration a list of major issues for rule-making; (2) describe and objectively critique NRC's current emergency planning
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process; and (3) define and recommend an approach for developing a compre-
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hensive plan that would fomulate the scope, direction, and pace for NRC's 752 'verall emergency planning activities.
(Specific responsibilitics were
=HE.r celineated in a memorandum from Lee V. Gossick dated June 11, 1979, and in a SECY ner.orandum dated June 12,1979.) Enclosure i lists members of the Task Force and a supporting Working Group.
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The Task Force has completed its assigned responsibilities, and herewith is reporting the results of its activities. The list of major issues developed r
by the Task Force was sent to the Comission via memorandum of June 19, and a discussion of each of the major issues was sent on July 17. The descrip-tion and critique of the current emergency planning process, which was discussed during a Ccmission briefing held on June 28, is sur:::nrized in.
Tho critique produced an extensive set of problem topics, which 2re also set forth in Enclosure 2.
The comprehensive action plan (Enclosure 2) presents staff plans for resolving the problem topics contained in Enclosure 2.
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The Comissioners.
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L% N o N R klR2 ii. T. Jamgochian (SD), in consultation wi a all progran effices, has precare) drafts of croposed amencments to f4RC regulations in crder to resclve many of the problems that have recently surfaceo in the emergency preparedness area (Enclosure 4). The Task Force members, recognizing that the specific language of the proposed regulations must be carefully assessed, unaninously supoort the t,asic principles presented in Mr. Jam;cchian's procesed changes.
Since State / local plan concurrence is to be a key factor in the ;r: posed regulation cha.nges and will impact on the decision to issue a license, serious considera-tion must be given to how this concurrence process is integrated into the responsibility of the licensing office.
Early comments and suggestiens frem the Ccmmissioners on these proposed amendments would be helpful to SD in pro-moting rapid development of the needed rule changes.
j Tnemas F. Carter, Jr., Chairman Tasi. Force on Eter,gancy Planning
Enclosures:
1.
List of " embers-Task Force and Working Group 2.
Cescription & Critique of ilRC's Current Emergency Preparedness Process 3.
Cor prehensive Action Plan 4
Draft Procosed Amendments to 10 CR Part 50 cc u/enciesures:
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<0-L. Bickwit, OGC
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S. Chilk, SECY A. sanneke, CPE O
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e Task Force on Emercency 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 Workino Grouc
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C. South, Group Leader, NMSS R. DeFayette, SP J. Dukes, SP J. Durst, RES F. Fisher, RMSS H. Gaut, SP J. Hegner, IE G. Kligfield, NMSS F. Lomax, NMSS R. Priebe, NRR M. Sanders, SP J. Sears, NRR J. Sniezek, IE l395 202 6
'A S 5._I..
DESCRIPTION AND CRITIQUE OF NRC'S CURRENT EMERGENCY PREPAREDNESS PROCESS *'
As a basis for future emergency planning activities, NRC's current emergency preparedness process was systematically described and analyzed for deficiencies or potential weaknesses. The descriptien 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 Emergency Precaredness Process c
To achieve an orderly and systematic description of NRC's emergency prepa. redness activities and to provide a means for an objective critique of that process, g
the working group developed a three-dimensional (4 x 4 x 7) matrix containing 112
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cells. One dimension of the matrix represented the classes of participants in the 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) Licensing; (c) I=plementation and testing; and (d) Actuel emergency respense.
The third dimension consisted of the following factors:
(a) Responsibilities; (b) Limitations; (c) Objectives; (d) Activities (expenditure of resources);
(e) Products, gceds, and services; (f) Organization (the entity perfonning the activities and/or delivering the products for the particular cell under consideration);and (g) Interfaces.
Use of this methodology forced a disciplined consideracion of the entire emergency preparedness pmcess. 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 emergency preparedness connotes the whole of planning, imolemencation, and' execution.
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and sometimes lengthy discussion'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 30 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) 1.icensing; (e) Implementation; and (f) Testing and Verification of Capability.
.y-The 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.
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 tem (six months or less). Others were seen as taking longer than six months. Still others were identified as amenable to both short-and long-ter:n 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.
1395 204 On the following list of problem topics a notation indicates whether the Task Force believes the problem can be solved entirely in the short term,
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partly in the short term,' or will require a longer time for resolution.
The 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 follows, 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.
Listino of problem Tooics A_
Resoonsibility/Authori ty Six proble= topics were identified in this important area of emergency planning and response. Some of the problems in other problem areas derive from omissions or lack of effective mechanisms described here.
In fact, sea.of those problems may not be amenable to solution unless
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these are corrected first, or at least concurrently.
A FRppNE* should be clarified Resolution:
Long ter n with resoect to NRC's Lead:
SP statutory resconsibilities.
Support:
NRR/NMSS/IE Under the FRPPNE* division of authority for control of Federal response at a licensed nuclear facility, the NRC leadership role is reduced to support status as soon as offsite casualties or widespread contamination occur. The icgic 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.
It may be, however, that the explicit and implicit concerns 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 she 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 nucle'ar emergency response planning.
It is not a Federal response plan, per R.
It has not been issued as permanent guidance. With one exception, che planning m
215 called for by NRC in the FRpFNE has bern done or continues to be done.
The exception calls for an MRC plan to resoond to a " Category III" incident where there is widespread radioactive contamination at a licensed nuclear facility in a remote area with limited usualties but significant property damage.
1395 205
continuing control of maily aspects of emergency operations at a licensed nuclear facility, even after offsite contamination and casualties have occurred.
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A Fomal arrangements are ill_-
Resolution:
Short and long term cefined for interacency ( F ederal,
Lead (FRPPNE):
SP State, anc local) cooraination.
Support (FRPPNE):
IE The crocess currently is on a Lead (IRAP):
' voluntary casts.
Support (IRAP):
NRR/tNSS/SP Federal agencies recognize the supremacy of State and local goverrenents to direct emergency response efforts within their jurisdictions. Those Federal agencies preparing emergency response plans, rules, and regulations have routinely ensured that those documents reflect the prerogatives of State and local authorities.
- Moreover, the integrated Federal -emergency response program as it exists today gives an almost similar sovereignty to the prerogatives and authorities of gh..
the Federal agencies who cooperate in the emergency planning. Hence, the limits
.g of cooperation, coord.i. nation, and designation of resources in the planning stage is essentially limited by the decision of each acency.
The primacy of State and local. authority in planning for emergency response will (and shculd) continue to exist, even though it consumes planning resources aryd complicates 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 intecrated Federal Resolution:
Short and long term mecnanism for tne funcing of Lead:
SP State anc local acenc'es to Support:
N/A succort raclological emergency creca rs:nes s.
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=a Other Federal agencies expend resources in assisting, and grantifig funds for, State and local agencies' general emergency planning.
NRC expends resources, not yet including grant funds, to provide assistance to State and local agencies for radiological emergency preparedness. There is no Federal mechanis:n for integrating NRC's effort with the other resource expenditure efforts.
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A Radiolocical Emercency Resoonse Resolution:
Long tenn Planning for transportation Lead:
NMSS accioents is inaceauate.
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 and 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 Needed to Improve
_3 Safety and Security."
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A NRC has not adeouately defined its Resolution:
Short tenn role in emercenev 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 oilly 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 term excess nis autnerity witn Lead:
NRR/NMSS rescect to offs 1te emercency Support:
IE/SP osanninc.
NRC requires the licensee's plans to provide reasonable assurance 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 7
voluntary, unenforcantle by NRC or the licensee on Federal, State, and local m.
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agencies and difficult to 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--by other agencies.
B For the emereeney elannine oracess.
Resolution:
Short tem no effective mechanism exists witnin Lead:
EDO NRC ror assurina consistency ano :ne Support:
All offices intecration of cuidance.
i.e., the error: 1s curren: y 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 organizational arrangements established to ensure that adequate ahd clear guidance results. This lack is particularly imoortant in view of,the 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. Al though infomal internal coordination among interested parties is practiced, it is by no means certain that all coordination that is needed is performed. Since some of the coordination is verbal, it is not easy to observe or reconstruct.
B NRC Incident Resconse Procram Resolution:
Shor-t and long tem neecs exoansion ano rurtner Lead:
IE ceveloement.
Support:
NRR/NMSS/SP Secticn 0502-01, Coverage, states " Guidance required fnr national level emergency planning is not currently included in this 'hapter.
With modification, 139S 208 4
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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 incomplete or delinquent parts of the NRC Incident Response Program should be provided. Not al.1 procedures or data required have been supplied to date.
B The licensee's olannina is Resolution: Short and lor g term basea on accidents of Lead:
NRR/NMSS severity uo to ano includine Support:
IE/SP/SD tne most serious aesign basis acc1 cents.
Prior to TMI there was no explicit recognition given to Class 9 accidents in the emergency planning process. TMI highlighted the question whether NRC should recuire emergency planning for Class 9 acciGants.
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Nh B The NRC resconsibilities.
Resolution: Long term
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delineated in FRPPNE"have Lead:
SP not oeen imolementea witnin Support:.
NRR/NMSS/IE/EDO the NRC.
The Federal Response Plan for Peacetime Nuclear Emergencies (FRPPNE)* identifies the NRC as an Operational Response Planning Agency (ORPA) for tw'o catecories of peacetime nuclear emergencies (PNE's) from a comprehensive set of fcur categories 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 opera *.ional response planning agency (s) type of PNE, for use by approcriate Federal supper.
agencies. This cuidance should include assumotions and casualty and crocerty damage estimates that can be used as a standard!
data base for clannina.
(c) Ensure that all functient essential to an effective response are included in the planning for which the operational planning agency has the lead responsibility. These functions shculd include the
- See footnote on page 3.
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technical ones, required to assess, counteract, and control the radiological effects; the humanitarian ones, designed to minimize the impact on individuals; and the recovery ones, directed at restoring essential services to the affected area.
NOTE: The functions included in the above responsibilities include but are not limited to these: notification, comunication, evaluation.
decision making, public information, law enforcenent, health and safety services, surviva* operations, international relations, and short term recovery operations.
B The need for research or studies in Resolution:
Short tem
- ne emeroency resconse area nas not Leat:
SP been comorehensively evaluated.
Suppcet:
All staff offices NRC has sponsored a modest research/ study program f.1 areas related to energency
- ilanning and response. However, it should be determined if additional efforts are needed to validate our current planning and response concepts.
- ian;g B NRC has no control over other Resolution:
Long tem acency resources assioneo to the Lead:
SP Reclonai Aavisory Comittees Support:
IE (RAC's).
The resources that other agencies supply to the 10 RAC's are deternined by then and are offered on a limited time basis. Therefore, the scheduling and coordination that ensues is captive to a v'oluntary and uncertain set of circ:r. stances that can produce variable results affecting quality of outpu?..
It is not clear that NRC's requirements will be met under this voluntary-arrangement.
Similarly, NRC's own representation to the RAC's is extremely limited and on an additional duty basis.
Reculations and Guidance C
Problems exist in the areas of both regulations and regulatory guidance.
Regulations are incomplete in some parts, and guidance is inadequr.te in ter=s of the lack of acceptance criteria and the frequent use of orther
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- than Regulatory Guides as a source of licensee guidance.
C NRC emercency olannino Resolution:
Short and long term culcance neeos irorovement.
Lead (Licensee):
HRR/NMSS Support (Licensee): All staff offices Lead (State / local):
SP Support (State / local): All staff offices (a)
It dcas not necessarily contain specific NRC acceptance criteria;
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(b) it is not restricted to that which is needed for implementing the '
ARC position as defined in Regulatory Guides (e.g., branch technical positions, bulletins, circulars,genericIctters,etc.).
While acceptance criteria can be developed for strictly licensee functions, there is a question whether the term " acceptance criteria" is applicable to the offsite elements of the emergency plan.
gg.g3 Because of the uncertainties rooted in the lack of criteria for an emergency
...g plan, most of the off_t.ite elements 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 terms should be issued.
C Reculations have voids or Resolution: Lonc term inconsistencies related to Lead:
50 emercency o sannino.
Support:
HRR/NMSS/IE/SP Part 50, Appendix E, requirements have not been applied to research reactors licensed prior to its adoption.
Part 30 does not require emergency plans or procedures.
Par. ?O does not require 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.
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C Protective Action G'uides have Resolution:
Short term not been oremulcated as Lead:
SP official receral culcance.
Support:
N/A If Protective Action Guides (PAG's) were promulgated as official guidance from the Federal government, it is likely that PAG's would be more uniformly adopted and implemented by all parties involved.
D, Licensino Four problem areas exist in licensing to meet radiological energencies.
Three of these relate principally to the capabilities and degree of commitment of resources external to the site for use during emergencies.
The fourth addresses the problem of NRC interaction with the public, during the licensing process, without a well-defined generic basis for
. response.
D Durino the licensine crocess, NRC Resolution:
Short term
.._T= uy coes not fuiiv assess actual-Lead:
NRR/NMSS gg.=
offsite caoability but limits Support:
IE/SP/EDO examination to tne eiecces or resources.
The licensing of facilities to assure an adequate response to nuclear emergencies 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 fo,rm of assessments or evaluations of these resources, at least in the numbers, types, training curricula, etc., but normally do not include a ecmprehensive 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 i: not direccly Lead:
SP relatea co tne i1censino orocess.
Support:
NRR/NMSS Present concurrence in State plans by NRC is neither necessary nor sufficient for the licensing decision-making process.
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9 0 The assistance to States is not Resolution: Long term farmaiiy couplec.to tne Lead:
SP licensine crocess.
Support:
NRR/NMSS The planning assistance that NRC provides to States, though s: mall currently, 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 Because of the lack of a ceneric Resolution:
Long term treatment of emereenev olannino Lead:
SD 1ssues in cuoile nearines, tne Support:
NRR/NMSS same contentions receatedly occur in puolic proceec1ncs anc DiaCe an undue 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 issues for use in rulemaking proceedings does not exist. Because of this lack of focus, the g
staff finds itself gojng over the same items time after time, winich is wasteful of scarce resources as well as distracting to the long-tem effort.
Imolementation
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This area held the most problems of all, a total of eight. They cover
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the range from interagency coordination to the pre-positioning and training 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 tenn been oiven to cooroinatino tne Lead (FRPPNE): SP Federal resoonse affectina Support:
IE 11censea fac111:1es.
IE Support:
NRR/NMSS/Sp Prior to TMI, the resources assigned to the task of integrating the NRC into
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_ a national emergency preparedness program were limited, and low in agency priority. That allocation of low agency priority (which is not unicue to NRC) hb b ?\\b
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is reflected in the fact' that the entire program has remained voluntaror, and, after years of planning, the FRPPNE is jocularly referred to as a " plan to plan."
E Licensino and insoection resources Resolution:
Short and long term neec excansion to cetter imolement Lead:
NRR/NMSS/IE their emeroency olannino efforts.
Support:
N/A Inspection and licensing efforts related to emergency planning are not in all cases closely integrated,, The necessary improvements in implementation will require increased resources.
E The majority of oceratine facilities Resolution:
Short and lcog tenn nave not seen evaluatec acainst tne Lead:
NRR/NMSS staff's current criteria for Support:
IE/SP emercencv osannino.
Sufficient resources are not avtMdble to review emergency plans of existing reactor licensees to bring them into conformance with present emergency planning criteria.
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E The incident resoonse criteria for Resolution:
Short term timelv notification cf the NRC Lead:
IE/SD neec to oe tianteneo.
Support:
NRR/NMSS/SP Some basic development of methods for triggering licensee notification procedures and of ensuring NRC recognition of the significance of information passed is required.
Setting of criteria for notification and predetensined action is.a delicate process of balancing the expense of notification / shutdown /
response to scme nonemergency against the need to ensure early detection of developing emergencies.
E-S - An orcanized " facility class Resolution:
Short term oriented" NRC resconse cacaoility Lead:
IE nas not oeen rusty estaoilsneo.
Support:
NRR/NMSS/EDO Based on the NRC role defined by the resolution of problen topic A-5, an efficient and timely response capability must then be instituted in order to cope with the evolution of any future emergency situation. Response should
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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 connunications to make the rapid assessment and response required.
E There is'a need durino an actual Resolution: Short term emeroency for near-to-the-site Lead:
IE Jacility to nouse tne multi-Support:
NRR/NMSS/SP acency coordination and resoonse Resolution: Long term succort activ1ty.
Lead:
EDO Support:
NKSS/NRR/IE/SP For sustained operations of a remote NRC response 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
-J.;i and arrangements made, including communications terminals and storage for
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data brought with the' team or accumulated during the emergency.
E-7 Need exists for excanded NRC Resolution: Short and long term mon-itorino caoacility.
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 IMI 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 ouolic information are not Lead:
EDO acecuate.
Support:
IE An adequate emergency response plan must include an effective system for informing the public, for updating the information as new developments occur,
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and for retracting,inforEation when it is found to be in error. Mistaken or false opinions that emanate from 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 infonnation sources, concurrence in factual infonnation released, and frequent updating of public infonnation should be fonnalized in the planning process.
F, - Testino ano 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-1 '- There has never been an NRC-wide audit Resolution:
Short tenn or tne emercency resconse runction.
Lead:
EDO Support:
N/A
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Although NRC has an gternal audit progrem, it has not applied a similar
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mechanism to itself for the emergency planning and response function.
F Evaluation criteria for drills /
Resolution:
Short and long tem exercises are no: cerinea.
Lead:
NRR/NMSS Support:
IE/SP/SD Although a varying degree of evaluation or assessment is associated'with the licensing process, NRC does not systematically evaluate the ongoing cacability for emergency response, particularly for offsite non-licensee 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 ter=s of likely performance but is limited to confidence that they will respond.
F There is no effective NRC Resolution:
Short and long tem meenanism for continued Lead:
SP evaluat1on of tne trainine Suppoi't:
IE ano cualification of key State anc tocal emercencv res::ense eersonnel.
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Even if the needed evaluition 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 perfoming their assigned mission. During 1975-1979, four independent reviews of NRC's emergency response program each stressed the need for utilities and State and local emergency planning officials to realize the im,aortance 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 developed 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.
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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 addr, esses the attributes of a coordinated NRC-wide emergency preparedness organization. The other five plans address problems specific to individual-pi v w m.. offices and were prepared by those offices. The six plans were Teach prepared to correspond to'the following format:
I.
Introduction II.
Su= mary and Conclusions -
III.
Responsibilities Relative to Emergency Preparedness IV. Current Program and Capabilities
_;equ' rements and fleeds V.
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VI. -Action Plan for Named Of fice The plans are presented below under the following tabs:
ORG, ilRR, NM55, IE, SP, and SD.
A summary of proposed actions follows.
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Summary of Procosed' Actions in Chronolocical Secuence 2
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Comoletion~
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Of6ce No/
Soecific Task August 1979 (IE)
B-2 Upgrade NRC Operations Center communications facilities.
August 1979 (IE)
B-2 Improve heating, ventilating, and air condi tioning for NRC Operations Center.
August 1979 (IE) & E-1 Meet with Forest Service concerning support to IRAP.
A-2 A-2 September 1979 (IE) & E-1 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 emergency response).
Define enb ronmental radiation renitoring capability.
October 1979 (IE)
E-7 October 1979 (IE)
E-2 Identify categories of material licensees for which emergency response plans should be required.
October 1979 (t;;G)
Rule PuSlish for coment proposed rule for which "early notice' was published on July 17, 1979.
.. ~. Decer:=er 1979
.(IE)
B-2 Uograde furniture and audiovisual support equipment in E"
NRC Operations Center.
Decerber 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 byproduct material licensee emergency pl ans.
January 1980 (NRR)
B-3 Complete the design review and prepare revised pra-cedu.res for post-accident sampling.
January 1980 (NRR) 3-3 Requi re improved in-pl ant iodine instru:r.entati on.
January 1980 (IE)
E-7 Order radiation monitoring equipment to establish an NRC environmental menitoring capability.
January 1980 (ORG)
Rule Publish final rule for which "early notice" was published on July 17, 1979.
January 1980 (IE)
E-7 Place TLD's' around operating power reactors.
A-2 January 1980 (SP) & E-I Stake out prominent role for NPI in cevelopment of the National Cont.ingency Plan.
A-2 March 1980 (SP) & E-1 Complete NRC agency plan for responding to nuclear accider s
Maren 1930 (SP)
A-2 Include appropriate language in HRC regulations related
& E-1 to State and local radiological emergency response plans on coordination among '.he various levels of government both in the planning and response periods.
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a Office No 3Decific Ta k March 1980 (SP) 8-4' ' Complete NRC agency response plan for peacetime nuclear emergencies taking into account responsi-bilitie,s outlined in FRPPNE.
March 1980 (NMSS) E'-2 Establish Environmental Radiation and Emergency Support Seetions,and coordinate its aetivity with IE and SP activities.
March 1980 (NMSS)
Prepare value-impact analysis for extending energency planning requirements to additional fuel-cycle and byproduct material licensees-April 1980 (IE)
E.- 7 '
Make initial collection of NRC's TLDs.
April 1980 (IE)
E-7 Develop supplemental budget for environmental tronitWng equipment not already on order.
April 1980 (IE)
E-7 Procun quipment/ data links for NRC nonitoring of operational parameters at nuclear plants.
April 1980 (SP)
A-2 Work with FEPA to seek a consensus among States
& E-l concerning the proper roles for State and local governments in radiological emerg'ency response.
(SP) 4 8-4 A-T Work with FEMA in the development of the President's April 1980
" National Contingency Pl an."
April 1980 (IE)
E-2 Revise IE Manual Procedures.
June 1980 (IE)
A-S Define NRC's role in emergency response.
June 1980 (SP)
C-1 Carry over into regulations the acceptance criteria concept for State and local government plans.
June 1980 (SP)
C-1 Work wir.h FEPA to develcp i:: proved handbook of guidance for Federal agency assistance activities with the States.
June 1980 (SP)
C-1 Work with FEMA to prepare an icproved emergency planning 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 plants using existing guidance and procedures.
June 1980 (SP)
.0-2 Begin codifying existing guidance to State and local agencies into regulations.
June 1980 (SP)
D-3 Work with FEPA to establish some Federal mechanim to certify emergency planning and response personnel of State and local agencies.
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a. Completion Prob.
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Date Office No.
Soecific Task 3une1980 (SP)
.B-6 Have FEMA re-establish the Regicnal Advisory Committees on a formal basis for all-hazards emergency planning, with HRC 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 communications between Emergency Operations Center.and plant.
July 1980 (NRR)
E-7 Improve off-site monitoring capability.
July 1980, (SP)
Assure adequacy of State / local plans against current criteris.
July 1980 (NRR) 0-1.
Conduct test exercise of power reactor licensee emergency plans.
July 1980 (SP).
Conduct test exercise of State emergency plans.
July 1980 (IE)
E-2 Pmeure equipment / data links for plant discharge moni to rs.
[ July 1980 (IE) 3-2 Develop procedures for inspecting byproduct material licensee emergency plans.
July 1980 (NMSS) E-3 Draft Reg Guide, Acceptance Criteria, and Standard Format and Content-documents for fuel-cycle and by-product material licensee emergency plans.
July 1980 (NRR)
C-1 Upgrade erergency plans for power reactors to meet
& E-2 Reg Guide i.101 with special attention to action level criteria based en plant parameters.
September 1980 (SD)
D-4 Resolve Cri tical Mass petition for Rulemaking.
Septeder 1980 (50)
'D-4 Revise Reg Guices 1.101, 3.42, and 2.6.
September 1980 (SP)
B-5 Prepare research study proposals based on analysis of studies new being done.
September 1980 (SP)
F-3 Work with FEMA to establish retraining programs for State and local agency persornel.
October 1980 (IE)
E-2 Commence inspection of byproduct material licensee emergency p%ns.
Decemoer 1980 (NMSS) C-1 Pursue rulemaking proceedings to require emergency plans for fuel-cycle and byproduct material licensees not new required to have these pians.
December 1980 (SP)
A-3 Wi:h FEMA, develop proposed rulemaking or lecislation te resolve the problem of funding for State and local agencies to suppcrt radiciogical emergency response olanning and precaredness.
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5 de Completdan Prob.
"T' Date Office No.
Snecific Task Deceder 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 adequacy of State / local plans against upgraded
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cri te ri a.
January 1981 (NRR/SP)
Conduct joint test exercise of Federal / State / local and power reactor licensee emergency plans for new Ots.
January 1981 (NRR) 5-7 Require high-range radioactivity monitors at nuclear
& B-3 power plants.
January 1981 (NRR)
B-2 Upgrade Emergency Operations Center in conjunction with in-plant technical support center.
July 1981 (NMSS)
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Update or suoplement 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 cocunents fer fuel-
-h cycle and byprcduct material licensee emergency plans.
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September 1981 (50)
' 0-4 Develop emergency planning regulations for research rea ctors.
Decader 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-4 Conduct joint test exercise of Federal / State / local and power reactor licensee emergency plans for all operating plants.
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ORG Action Plan August 8, 1979
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t-NRR Action Plan August 2, 1979 by L
Brian Grimes
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i NRR Action Plan
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INTRODUCTION
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II.
SUtHARY AND CONCLUSIONS III. NRR RESPONSIBILITIES RELATIVE TO EMERGENCY PREPAREDNESS NRR reviews the emergency plans submitted by the licensees according to the requirements of Appendix E to 10 CFR 50.' The Accident
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Analysis Branch, DSE, pe~rforms a review of the licensees' plans prior to issuance of an OL.
The Environmental Evaluation Branch, DOR, reviews any modifications to the emergency plans of operating reactors. Currently two professionals in AAB and one in EES are assigned to thse tasks.
IV.
CURRENT NRR PROGRAM AND CAPABILITIES I'.=I' In order to upgrade the emergency plans for all operating reactors
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and near term OL applications,' DOR has established a task force consisting of a NRR team leader, a member of the technical staff of LASL, who will provide technical assistance to NRC, and in.IE member. These teams will review the licensee's emergency plans for compliance with Regulatory Guide 1.101 and the recommendations of the NRC/E?A task force NUREG-0357. The review will include an on-site evaluation of the licensee's emergency planning provisions, including his interaction and coordination with local and state authorities.
The schedule for these reviews will assure ccmpletion of the review of all operating power reactors by July 1980.
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July 23,1979 SECY-79-450,
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For:
The Commissioners g
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Executive Director for Operations Frcm:
Harold R. Denton, Director, Office of-Nuclear Reactor Regulation
Subject:
ACTION PLAN FOR PROMPTLY IMPROVING EMERGENCY PREPAREDNESS
Purpose:
To infom the Commission of the staff's plans to take immediate steps to improve licensee preparedness at all operating power plants and for near-tem OL's.
Discussion:
While the emergency plans of all power reactor,1,i.censees:_.
have been reviewed by the staff in the past fo'r confomance to the general provisions of Appendi.t E to.10 CFR Par: 50, the most recent guidance on emergency planning,.primarity that given in Regulatory Guide 1.101 " Emergency Planning for Nuclear Powe'r Plants", has not yet been fully implemented by most reactor licensees.
Further, the. e are some ada'itional areas where improvements in emergenry planning have been w
2EE highlighted as particularly significant by the Three Mile 2E" Island' accident.
The NRR st'aff plans to undertake an intensive effort over about the next year to improve licensee preparedness at all operating power reactors and those reactors scheduled for an operating license decision within the next year.
This effort will be closely coordinated with a similar effort by the Office of State Programs to improve State and local response plans through the concurrence process and Office of. Inspection and Enforcement efforts to verify pecper implementation of licensee emergency preparedness activities.
The main elements of the staff effort, as listed in Enclesure 1, are as follcws:
(1) Upgrade licensee emergency plans to satisfy Regulatory Guide 1.101, with special attention te the development of unifom action level criteria based on plant parameters.
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The Commissioners, *
(2) Assure the implementation of the related recommenda-tions of the NRR Lessons Learned Task Force involving instrumentation to follow the course of an accident and relate the information provided by this instrumentation to the emergency plan action levels.
This will include instrumentation for post-accident sampling, high range radioactivity monitors, and improved in-plant radiof odine instrumentation. The impl ementation of the Lessons Learned recommendation on instrumentation ~
for detection of inadequate core cooling will also be factored into the emergency plan action Tevel criteria.
(3) Determine that an Emergency Operations Center for Federal, State and local personnel has been established with suitable communications to the plant, and that upgrading of the facility in accordance with the Lessons Learned recommendation for an in-plant technical support center is underway.
(4) Assure that improved licensee offsite monitoring capabil-ities (including additional TLD's or equivalent) have been
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provided for all sites.
('5T Assess the relationship of State / local plans to the
=r licensee's and Federal plans so as to assure the capability to take appropriate emergency actions.
Assure that this capability will be extended to a distance of 10 miles as soon as practical, but not later than January 1,1981. This item will be performed in conjunction with the Office of State Programs and the Office of Inspection and Enforcement.
(6) Require test exercises of approved Emergency Plans (Federal, State, local, licensees), review plans for such exercises, and participate in a limited number of joint exercises. Tests of licensee plans will be required to be conducted as soon as practical for all facilities and before reactor startup for new licensees.
Exercises of State plans will be perfonned 7nC
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NMSS Action Plan August 8, 1979
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by F. Fisher G. Kligfield F. Lemax
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nugusu u, exis NHSS ACTION PLAN FOR EMERGENCY PREPARE 0 NESS
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NMSS has been planning an emergency preparedness program for some time and has recently begun implementation of that program with the formation of the Environmental Radiation and Emergency Support Section (ERESS) in the Uranium Fuel Licensing Branch of the Division of Fuel Cycle and Material Safety. The activities of the ERESS include development and implementation of an emergency preparedness program which redresses, among other things,.those deficiencies identified as " program topics" by the NRC Task Force on Emergency Planning with its Working Group, and for which NMSS was designated as the lead office or as sharing lead office responsibilities. This Action Plan describes NMSS's preliminary plans for addressing each of those " problem topics".
II.
SUMMARY
AND CONCLUSIONS A plan for a Radiological Emergency Preparedness Program has been developed by NMSS and has been partially implemented with the formation of the Environmental Radiation and Emergency Suppor: Section (ERESS) in the Uranium Fuel Licensing Branch of the Division of Fuel Cycle and Material Safety.
ERESS will, in the short term, greatly augment NMSS capability in discharging its radiological incident management responsibilities, primarily through the assembly and organi::ation of information on activities of its licensees, and will initiate rule changes and development of guides, review criteria, etc. suitable for emergency planning programs appropriate for NMSS and selected fuel cycle and
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3)p byproduct material li.censees.
I.n the long term, NMSS will extend the require-ments for approved emergency plans to all pertinent NMSS licensees through
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rule making and will develop and premulgate appropriate licensee guidance.
An appropriate regulatory capability will be installed that includes staff, staff training, emergency plan review and acceptance criteria, information resources, and necessary analytical tools.
III. NMSS RESPONSIBILITIES RELATIVE TO EMERGENCY PREPAREDNESS NMSS has the general responsibility for the protection of health and safety, the environmen'., and property from adverse effects due to the activities
- of fuel cycle and byproduct material licensees.
IV. CURRENT NMSS PROGRAM AND CAPABILITIES NMSS had at the time of the TMI-2 incident only a limited radiological contin-gency planning program. All 10 CFR Part 50 licensees and scme Part 70 activities, i.e., processing and fuel fabrication, scrap recovery, and conversion of uranium hexafluoride, are required to have approved emergency plans.
In addition, a few Part 30 and Part 40 licensees have emergency plans and procedures incorporated by reference into their license conditions.
In general, the scope
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A.
Details of problem Although a varying 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-licensee resources.
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 terms of likely performance but is limited to confidence that they will respond. NMSS reevaluates, to some extent, during license renewal reviews, i.e., every 5 years.
B.
plannino Basis for Action NMSS will apply the same criteria for review of applicants' emergency plans and the assessment of support organization capabilities related to license renewals as are applied to applications for new licenses or newly required emergency plans.
Reassessment criteria and procedures for non-renewing NMSS licensed facilities will be developed when such facilities are licensed.
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Action plan Short Term 1.
NMSS is presently reviewing post-licensing emergency plans for fuel cycle facilities on a pre-TMI-2 basis. New criteria will possibly require a second review.
2.
NMSS will review any emergency plans submitted in. support of renewal applications to the same post-TMI-2 criteria as will be applied for new licensee applications.
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Lone Term 3.
This item will be ' integrated with development of criteria for review of new emergency plans.
4.
At 5-year intervals, all. active NMSS activities are renewed and emergency plans will be reevaluated at those times to criteria identical to those then current for new plans.
5.
At such time as licensed production and utilization facilities are active, NMSS will develop and/or adapt from NRR, criteria and procedures for post-licensing reassessment of emergency
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N IE CiERGENCY FLANNING ACTION PLAN August 3, 1979-
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by D. Themosen J. Snie:ek J. Hegner 1395 231 DUPLICATE DOCUMENT Entire document previously entered into system under-ANO No. of Pages:
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SP EMERGENCY FLANNING ACTION PLAN August 5, 1979
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by H. Collins M. Sanders 1395 232 DUPLICATE DOCUMENT
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SP ACTION PLAN FOR E"ER'iENCY FREPAREONESS
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I.
INTRODUCTION The Office ~of State Programs is responsible for two elements of the NRC' emergency preparedness program:
assisting State and local govern =ents in radiological emergency response planning along with other Federal agencies; coordinating the NRC r.ctivities for responding to national emergency conditions, known as the national. emergency preparedness program.
Both of these activities have been essertially outside the licensing process and outside the NRC Incident Response Program.
II.
SUM'4ARY AND CONCLUSIONS This SP Action Plan addresses the major work remaining in the two SP emergency preparedness activities and the resources neededa It emphasizes
-ihI4 the demands that are likely to be placed on SP (and other NRC offices)
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as a result of legislative initiatives. The action plan, along with those of NRR, IE and NMSS, reflect significant involvement of State and local government emergency planning in the NRC licensing process.
III. OFFICE OF STATE PP0GRANS RESPONSIBILITIES RELATI'/E TO EMERGENCY
. PREPAREDNES5 A.
Radiological Emercency Resoonse Planning.
The Office of State Programs carries out the NRC's " lead agency" responsibilities among involved Fedtral agencies for assisting the States and local governments in developing radiological emergency response plans supportive of fixed nuclear facilities and for transportation accidents involving radioactive =aterials.
NRC's responsibilities, and the responsibilities of other involved Federal agencies, are assigned in a Federal Register Notice of December 24,1975 (4C FR 59494) and in MRC Manual Chapter 0141.
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SD EMERGENCY PLANNING ACTION PLAN August 8, 1979 EXE by w
P. Comella M. Jamgochian f395 234 o
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novo.. v, i s,1 SD ACTION PLAN FOR EMERGENCY PREPAREDNESS L;_-
I.
INTRODUCTION Purcose This plan was developed to provide SD coordination with other NRC office activities identified as " problem topics" by the NRC Task Force on Emergency Planning.
Need Because of the fragmentation within NRC of various emergency planning activities, such a plan is neces_sary to identify clearly areas of Office responsibility, and more appropriately. assure that no aspect of the
" problem topics" is excluded.
Scoce This Action ' Plan addresses only those " problem topics" identified
, orig.inally by the Working Group and later modified by the Task Force, for which SD is the lead office.
II.
SU". MARY AND CONCLUSIONS
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ihe Action Plan basically calls for revisions and additions to existing
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emergency planning regulations, regulatory guides, NUREGs and ANSI standards, as well as our coordination.with other Federal agencies.
Long-term success of the plan hinges on the explicit definition of NRC's role in responding to an incident.
III. SD RESPONSIBILITIES RELATIVE TO EMERGENCY PREPAREDNESS
- Write, revise, and keep current emergency planning regulations, regulatory guides, NUREG reports, and ANSI standards.
Provide input for NRC Incident Response Program.
Provide input for the NRC Operations Center.
Coordinate with other' Federal agencies in support of NRC emergency planning activities.
IV.
CURRENT SD PROGPAM AND CAPABILITIES SD emergency planning activities are basically programatic, which include:
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