ML19305E201
| ML19305E201 | |
| Person / Time | |
|---|---|
| Issue date: | 01/28/1980 |
| From: | Goller K NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML19305E191 | List: |
| References | |
| NUDOCS 8004230110 | |
| Download: ML19305E201 (7) | |
Text
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January 28, 1980 MEMORANDUM T0: Robert B. Minogue, Director Office of Standards Development FROM:
Karl R. Goller, Director Division of Siting, Health &
Safe 5uards Standards
SUBJECT:
WORKSHOPS ON PROPOSED EMERGENCY.PLANNIf!G RULE CHAT:GES Four workshops on the proposed NRC emergency planning rule changes were held in NYC, San Francisco, Chicago and Atlanta on January 15,17, 22 and 24, respectively.
The workshops were held with invited State and local government officials and utility representatives and other interested individuals from the public that attended. is a typical agenda for the workshops. is a table which summarizes the attendance and participation at each of the four workshops.
The morning session of formal presentations at the NYC workshop proceeded well, but the afternoon session was interrupted and not allowed to proceed -
in an orderly manner.
This occurred because of the unruly behavior.of large numbers of representatives of various public groups, who insisted on spehking then, rather than at the time provided for them in the agenda.
As a result, the time avaliable to obtain comments from invited participants was limited and their commentary was inhibited. A major portion of this workshop was therefore devoted to hearing statements against nuclear power in general and for the immediate shutdown of the Indian Point Plan,t in particular.
Some comments were received frca invited participants during the question / answer portions of the morning session, but more iccortantly invited attendees did get a better understanding of the proposed rule and it did serve to focus
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their attention on it, which should improve the written comments which many of these participants indicated. they will submit.
The different kind of information obtained at the NYC workshop supplements that from the other workshops. This is the views and intenseness thereof of at least one faction of the public on nuclear power in general and the Indian Pcint fagility in particular, and lessons on how best to arrange for and conduct such public workshops or meetings. A memo /recort will be prepared that summarizes the lessons learned from the entire series of workshops on how to hold such public meetings.
One suggestion in this regard stands out, and is therefore worth stating here, i.e. the NRC should develop oregoing,.
centralized expertise in the administrative support and mechanics of conducting public :..te;ing;, probcbly in ADM.
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vg-Robert B. Minogue.<
The other three workshops, in San Francisco, Chicago and Atlanta were conducted almost exactly in accordance with the agenda.
In all these cases, attendance by the general public was much smaller and quite orderly, and the objectives of the workshops were fully achieved.
A mutually useful dialogue took place between the NRC and FEMA staffs and invited participants and many significant-comments on the proposed rule changes were received.
Many of the participants indicated their intent to supplement their comments with written submittals.-
Detailed information on all the workshops, including the names and affiliations 3
.of all participants and speakers from the general public and a summary of all 1
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significant cpmments received will be prepared, published as a NUREG report
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and a copy provided to each participant within the next few weeks.
In 'the interim, Enclosure 3 provides a summary of the more important comments received at one or more of the workshops. There was considerable repetition of comments at the workshops, especially of the more significant comments.
All the comments listed in Enclosure 3 were made more than once.
In summary, I would like to say that the overall success of the workshops was due largely to the dedication and cooperation of all the NRC and FEMA staffers (which are listed in the ce list below) who made the arrangements for and/or participated in the workshops.
It was truly a team effort.
Y S h4 Karl R. Goller, Director Division of Siting, Health &
Safeguards Standards
Enclosures:
As stated cc: w/ enclosures
- 5. Schwartz B. Grimes E. Conti M. Jamgochian R. Voegeli A. Morrongiello B. McCarthy P. Kaplan C. Gomez C. Abraham, Region I J. Hanchett, Region V J. Strasma, Region III K. Clark, Region II John W. McConnell, FEMA j
Seymour Wengrovitz, FEMA i
U5. NUCLEAR REGULATORY C0'4 MISSION Chicago, January 22, 1980 EMERGENCY PREPARE 0 NESS WORKSHOP AGENDA Mornino Session 8:30.- 8:45 a.m.
Introduction - Session Chairman
- Purpose 5 Scope of Meeting Karl R. Goller Director
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- Background-Reason for Proposed Division of Siting Health Rule and Safeguards Standards
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- Proposed Rule Provides for Office of Standards Development J
Federal / State / Local Planning for Emergencies
- NRC Emergency Planning Require-ments-Concurrence Required 8:45 - 9:30 a.m.
Presentation of Procosed Rule
- Rationale for and Description Michael T. Jamgochian of Proposed Rule Division of Siting,' Health
- Differences in Requirements and Safeguards Standards for Emergency Planning Zones, Office of Standards Development i.e. Plume Exposure Pathway Zone compared to Ingestion Pathway Zone 9:30 - 10:15' a.m.
- Criteria to be Met for Brian K. Grimes, Director Concurrence Emergency Task Group
- Who Must Have Concurrence?
Office of Nuclear Reactor
- Review and Concurrence Regulation
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Procedures 10:15 - 10:30 a.m.
BREAK 10:33 - 10:45 a.m.
Federal Emeroency Manacement Acency (FEMA)
Role in Overall Emergency Preparedness, John W. McConnell Training, Funding, and Model Plant Assistant Associate Development Director for.Po~pu-lation Preparedness Federal Emergency Managemen't Agency 10:45 - 11:00 a.m.
Public Affairs Jan Strasma Public Affairs Officer Role of Public Affairs Officials Region III in an Emergency, Coordination Office of Public Affairs
' Between " Responders" and the Media m
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Mornino Session (con't.)
11:00 a.m. - 12:00 Questions and Cem=ents From General Public 12:00 N - 1:00 p.m.
LUNCH' Afternoon Session 1:00 - 4:15 p.m.
Discussion By Particioants Karl Goller Session Chairman Discussion Points:
- Requirements that State and l'ocal emergency response plans be concurred in by the NRC as a condition of operating license issuance.
(NRC concurrence in State and local plans is not required at the construc-tion permit stage.) Additionally:
a.
An operating plant may be required to shut down if a State or local emergency plan has not received NRC concurrence within 180 days of the effective date of the final amendments, or January 1, 1981, whichever is earlier.
b.
An operating plant may be required to shut f'wn if a State or local emergency plan does not warrant continued NRC concurrence and is not corrected within 4 months of notification of NRC concurrence withdrawal.
(Discussion will include consideration of al.ternative proposed rules for penaitting continued operation or issuance of operating licenses for an interim period where there are no concurred in p'lans or concurrence has been withdrawn. )
- Requirement that emergency planning be expanded to cover " Emergency Planning Zones."
- Requirement that detailed emergency planning implement-ing procedures be submitted to NRC for review.
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- The requirement that specified " Emergency Action Levels" be used by the applicant, State and local authorities.
- Provisions for prompt alerting of the public and instructions for public protection.
- Requirements for having Emergency Operations Center.
Requirement for providing redundant ccmmunications systems.
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=4 3-a Afternoon Session (con't.)
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1:00 - 4:15 p.m.
- Requirement for providing specialized training to licensee and local emergency support personnel.
- Requirement.for maintaining up-to-date plans.
- What meas'res can compensate for various u
deficiencies.
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4:15'- 4:30 p.m.
BREAK 4:30 - 5:00 p.m.
_0uestions and Comments by the General Public e
6:00 - 8:00 p.m.
DINilER 8:00 - 11:00 p.m.
Evenino Session
- Additional Public Comments 11:00 p.m.
ADJOURN
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ATTENDANCE A PARTICIPATION AT WOQXS40PS Invited States General Speakers from Attendees Reoresented Public General Public Attendees
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NYC 100 12 several hundred 74 San Francisco 45 13
~ 50 19 (2)
Chicago 50 9
m 100 A ?.
Atlanta 80 14 7
50 7
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(I)l. 0 signed-up to soeak; but, after more than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of questions, 1
comments & statements from the public, time ran out at 11 pm at night (2)about 10 of these spoke in two groups r
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-c Major Comments Received at Workshoos 1.
Shifting the burden to the licensee in case of lack of NRC concurrence or withdrawal of concurrence on State and local government emergency plans violates the Atomic Energy Act.
2.
Concurrence, non-concurrence and/or concurrence withdrawal musti be based
.on criteria established by rule, not in a 'NUREG report.
3.
Who is going to pay for the development, implementation-and ongoing maintenance of the State and local government emergency plans.
i 4.
The schedule for implementation of the proposed requirements on i
development, implementation and concurrence in State and local government emergency plans is entirely too short.
Good specific reasons for this comment were presented.
5.
Rule should be clear on procedures for NRC finding of non-conformance, and should include provisions for "due process" and hearings.
i 6.
Distinction between NRC and FEMA responsibilities and authorities should be clarified, including the extent of participation of these and any s,
other Federal agencies in accident response.
7.
Concern about the possibility of a State or local government simply not' developing or implementing concurrable emergency plans for any reason, (and numerous specific, phusible reasons were presented) and thereby blocking the licensing or operation of a plant.
8 Invited participants were almost unanimous in recommending Alternatives A (Commission action) relative to the three pairs of alternatives or.
i NRC concurrence or withdrawal of concurrence on. State and local ' emergency plans.
However, all speakers from the general public that address this question were also almost unanimous in recommending Alternative B (automaticshutdown).
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9.
Requirements for~ prompt notifications by licensees and by State and/or <
i local governments (15 minute guideline value) need to be clarified and
'probably relaxed.
10.
Many of the speakers from the general public stated that it is impossible to evacuate high density population areas and theref, ore that the " planning" i
required by the proposed rule is a ' farce.
Many specific, supposedly insurmountable problems associated with evacuation were cited, including the large numbers involved, lack of adequate evacuation routes, the many s'pecial cases that need to be considered such as children, the aged, invalids,
'the blind, ciippled, non-English speaking, etc.
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