ML19341B803
| ML19341B803 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/23/1981 |
| From: | Mcnees J ALABAMA, STATE OF |
| To: | Dunesia Clark Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8102270628 | |
| Download: ML19341B803 (5) | |
Text
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State of Alabama s
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DEPARTMENT OF PUBLIC HEALTH
' ick State Office Building
,5 Montgomery. Alabama 36130 s
IR A L MYERS, M.D.
February 23, 1C)81 STATE HEALTH OFFICER Mr. Dick Clark U. S. Nuclear Regulatory Commission Division of Licensing Washington, D.C.
20555 Re:
FE'1A flP Guidance Mema 1 17
Dear Mr. Clark:
The enclosed document has been distrubuted to the States in this region for use in future radiation emergency plan drills at nuclear power plants.
It lists extensive interaction between the States, FEMA, and NRC that have not occured at past such drills and exercises.
Most notable of these is a joint feleral critique the day after the exercise where NRC discusses on-site and FDIA discusses of f-site.
Past activities were not conducted ir. this manner in Alabama.
We are in the planning stages of the acceptance exercise for tne Browns Ferry Nuclear Plant.
Inorder to be prepared for the eventu-allties, we request clarification as to the extent the NRC will follow FDIA REP Guidance Memorandum d 17 at futurn exercises in Alabama.
Sincerely, James L. McNees Radiation Physicist Division of Radiological Health m
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Please a:ranga to have the attached guidance isomerandst pub 11 ^=a in the -
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In coc rdination with Inc, the attached joint exercise procedures have been oevealoped. The objective la to establish mors r.iformity in the Radio'L~-1 -=1 taurgency ?reparedness exercises undar the proposed.?DLA Rule.44 Cyx 350.
1 Since the F2ih *nnle" speaks to eff-sita. activity, the exercise procedtsraa, '
er.aphasuo that aspect. 11curver, in recognition.cf the paralla1.1.nvolvesmat,.
of toe ::R":, their activity is shown in direct relation to.:r:ptA*s'.7 'J.;.'.{'. '
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1 20 have also discussed with the Wrc tmr desirs for completion of all plans
.and exor=ises by April 1, 1981.
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.scos licc= sees who will mot be ready to exercise ef fectively.zatil after 1
this data. Therafore, while imA zuet ocntinne to press for inplementation cf ststo and local plane by April 1, Regicms 'must be flexible in sched.smg
- of goin: exercises in support of the " Rule". Tacilities should not be forced -
into pre-April exercises if they are w; ready,. since premature inaolvement..f~
of the f acility works against the deve'et of integrated preparma,=es.
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hope that this approa=h will help in sch=A die-5 your exercises secre effectipe.ly..
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Guidance Memorandum 17~
Radiological Emergency Preparedness Division JOINT EXERCISE PROCEDURIS In the interest of assuring that the health end safety of the public is protected in the event of an accident at a nuclear power plant, it is necessary for the licensee (applicant), to conduct an energency preparedness exercise jointly with appropriate State and local agencies.
The role of the Federal government at such exercises is to evaluate the capability of the utility and the State and local governments to protect the public health and safety in the event of an accident at the facility.
The FEdA official responsible for this activity is the appropriate Regional Director.
Over the last few months there have been several jcint exercises where FEIA and URC have made reviews both orally in an open meeting, and in written form.
We find however, significant variation among regions in the procedures used for providing the evaluation. The need for a standardised approach is evident and the following is a guide for both FE4A and NRC personnel involved in exercise evaluation.
i Assignments for offsite observers will be made by the RAC Chairman.
Casite observers will be assigned locations by the URO Team Leader. A meeting of all parties shculd be conducted prior to the exercise to assure that all observer locations are staffed by an evaluator, as well as to make whatever last minute changes are necessary based en field conditions, nu=ber of evaluators available, etc.
The exercise should be followed as soon as possible by a critique. The critique is a working session for preliminary revies: of the exercise between the participants (State and local officials and utility representatives and the Federal observer teams headed by FE4A and the NRC). It should be open to the public and the media. They should, however, attend as observers, and not participate in the discussions. If local circumstances dictate that a private session Le held with the State authorities, it must be scheduled in advance and the information provided by the RAC Chairman at the private f
=eeting should be repeated in the open session.
. It is desirable to conduct the critique eith all the principal parties present, (e.g. the RAO, the involved Sta e and local authorities, the licensee and NRO).
There may be situations where such a joint critique is not feasible and separate sessiens (one related to licensee participation and one related to State and local participation) are necessary due to logistical or funding constraints.
These situations are to be cleared in advance thru the FE4 A/NRO Steering Ccerdttee.
In such cases the RAO Chairman should be availab e for both cri~iques.
The joint critique should be chaired by the RAC chairmen and should be within or near the 10 mile EPO.
As part of the overall f ormat the RAC Chairman will discuss observations of the offsite response and the NRC will discuss observations of the onsite response.
The State, local governments and utility should be present at this meeting to eake pre-sentations.
For the joint critique to be effectiva, it should take place within the 24-hour period immediately following the exercise.
':. tere should also be opportunity for clarification, questions or cc=ments by licensee, State and local officials.
The RAO Cha:.r an's overview stateunt should be based on comments froct RAC members and other FE4A observers as well as his own observation.
It should include the strong points as well as a general statement en the deficiencies noted.
Under no circumstances will the RAC Chairman's comments indicate that the State or local plans passed or failed.
He/she should indicate that the co=ments are preli=inary to be followed by a comprehensive evaluation within 14 days.
The final FE4A findings and determination, as well as approval of a State and/or local plan, su' emitted according to 44 CFR 350 of which the exercise is a part, is reserved to the Associate Director for Plans and Preparedness in Washington.
The principal =ilestones for FE4A and NRO exercise observation and critique are given in Enclesere 1.
These milastones are for planning purposes and actual schedules may nsed to be different because of local circumstances.
Enclosure No. 1 MILESTONES FOR EXERCISE C3SEK7ATICN AND CRITIQUES 75 days' state and licensee jointly submit exercise objective to FEHA and NRC Regional Offices.
60 days FE3A and NRC Regional Offices discuss and meet with licensee / State as necessary and prepare response.
45 days State and licensee scenario developers submit exercise scenario to FE4A and NRC Regions for review.
35 days FE4A and URC Regions notify State and licensee of scenario acceptability.
30 days FE4A and NRC Regions develop specific post exercise critique schedule with the State and advise FDtA and NRC headquarters.
15 days The RAC Chairman and NRC team leader will meet to develop observer action plan (where stationed, how many from each organi=ation, what to look for).
1 day Maeting, in the exercise area, of all Federal observers both I
onsite and offsite to finali=e, assignments, and give instructiens.
E day Exercise l
E day PE4A and RAC observers caucus to collate observations.
NRC observers also caucus to collate observations.
E day RAC Chairman.and NRC team leader meet, as,soon after their t
respective caucuses as practical, to coordinate Federal participation in critique.
E to + 1 day Joint RAC/NRC critique General Acenda A.
State, locals and licensee present their views.
B.-
Critique of offsite actions, by RAC Chairman.
C.. Critique of onsite actions, by NRC.
D.
Critique of Federal response (if applicable), by RAC Chairman.
E.
Opportunity for clarification questions or comments by licensee, State and locals (press and public questions will not be entertained during the critique).
15 days Written critiques by TE1A Region. to State, with cepies to FE4A
+
headquarters and NRC ~ and by NRC Region to licensee with copies to NRC headquarters and FEMA.
- (Recommended Suspense Dates)-
.