ML20027C110

Transcript of 820918 Public Meeting in Washington,Dc Re FEMA Briefing on Offsite Appraisals Program.Pp 1-63. Viewgraphs Encl

ML20027C110
Person / Time
Issue date:	09/18/1982
From:	NRC COMMISSION (OCM)
To:
References
REF-10CFR9.7 NUDOCS 8210120581
Download: ML20027C110 (87)

Text

{{#Wiki_filter:_ _ _ - _ - - __-_ r. i p**" %, e I /w d% h-mime d h em na:--m 4 J eut a

3. t. -s, y n a c:an s eus m y s v s

~ s voco :s s 1 y-v m t-

1. NUCLEAR REGULATORY COMMISSION i

g, ,e s. l ..r** i 1 e a i i l' 1 i f FEMA BRIEFING ON OFFSITE APPRAISALS PROGRAM - 1 I l l 1 i, PUBLIC MEETING e l I 4 l l I 1 Friday, September 18, 1982 i Pages 1 - 63 Prepared by: LYNN NATIONS Office of the Secretary I ~rB2101205s1 820918 I iPDR 10CFR PTT.7 PDR

s -4_ i DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Comission held on Friday, September 18,198ih the Commission's offices at 1717 H Street, N.W., Washington, D. C. The meeting was open to public attendance and ' observation. This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies. The transcript is intended solely for general informational purposes. I As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determinations or beliefs. -No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or argument contained herein, l except as the Commission may authorize. f.

1 1 UNITED STATES OF AMERICA 2 C.- NUCLEAR REGULATORY COMMISSION 3 r 4 5 FEMA BRIEFING ON OFFSITE APPRAISALS PROGRAM 6 PUBLIC MEETING 7 8 9 Commissioners Conference Room Room 1130 10 1717 "H" Street,.N.W. Washington, D. C. Friday, September 18, 1982 12 The Commission met in open session, pursuant to notice, at 10:00 o' clock a.m., NUNZIO J. PALLADINO, Chairman 14 of the Commission, presiding. 15-COMMISSIONERS PRESENT: 16 NUNZIO J. PALLADINO, Chairman of the Commission JOHN F. AHEARNE, Member of the Commission VICTOR GILINSKY, Member of the Commission 17 j JAMES K. ASSELSTINE, Member of the Commission h 18 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE: . e j 19 W. DIRCKS a R. DeYOUNG 'M J. ZERBE 20 i L. TiiOMAS A R. KRIMM { 21 V. ADLER i 22 23 - 24 l (- 25

2 4 1 P"R 0 C E E D I N G S 2 CHAIRMAN PALLADINO: Please come to order. The purpose of this meeting this morning is to have a Federal 3 Emergency Management Agency, FEMA, brief the Commissioners 4_ on the results of its reviewed use of offsite emergency response plans around nuclear power plants. 6 FEMA's role in 'this regard involves the evaluation of a capability of state and local governments to actually 8 carry out emergency actions that may be necessary in the 9 event of a nuclear powe plant accident. With us this morning is Mr. Lee Thomas who is 10 ' FEMA's associate director for state and local programs and support and I will ask him to introduce his colleagues when 12 I turn the meeting over to him. F First, do any of the other Commissioners have any openingremarksh' 14 s 15 (.No response.) to CHAIRMAN PALLADINO: In that case, then I will turn 'f the meeting over to Mr. Thomas. 37 t MR. THOMAS: Thank you, Chairman Palladino. With '18 y 8 me is Dick Krimm who is assistant associate director for

j 19 natural and technological hazards and Vern Adler who is j

20 director of our technolog;.gl hazards division. J 21 (SLIDE.) 22 MR. THOMAS: What I wanted to do today is to respond to the equest of the Commission to talk about 23 offsite deficiencies and basically where we are and what we .{ have learned over the last couple of years as we have moved t l 25 forward jointly to assess c ffsite preparedness.

3 1 I would like to start off by saying that one, I think 2 { we have learned a lot. I think the states and locals that 3 we have worked with have as well. I personally feel like 4 there has been a significant amount of progress as far as state and local government is concerned and their capability 5 to respond as well as insure. preparedness around fixed nuclear facilities in the country. I think that has been 7 the result of a tremendous result on their part and in most a cases jointly with the utilities involved. '8 Additionally, I think it has been the result of to a tremendous effort on the part of your agency and our agency as well as the other federal agencies to support state and 11 locals in the job that they had to do. In that regard there are deficiencies that we have 13 noted that ..e will call generic deficiencies in offsite pre-14 paredness. I want to put in context though before I get to 15 the specifics of what we mean by those generic deficiencies. 16 It does not necessarily mean that one of those deficiencies 17 is such that we would recommend to you that there was a e significant deficiency in offsite preparedness or that two 18 of them were. j 19 y Just as we look at deficiencies in any specific 20 situation, we have to look at it in the context of both 21 'their plan as well as their capability to respond. We have l 22 to look at.the total system, the total' ability of both the ~ 23 state and the local ' units of government to respond and if 24 there is a deficiency at one place, it may well be that ( it is compensated for by a capability at another place. 25 So it is a systems approach and it is a system that

4 s ~ 1 we have to look at before we give you a bottom line assessment 2 ( as far as what that capability is, just as you have to do '3 the same thing when you look generally both onsite and at 4 our offsite findings in making your decision on whether their is a capability there to respond. 5 (SLIDE.) 6 MR. THOMAS: Let me before we go to the specifics 7 talk to you just generally about FEMA's role. FEMA's role 8 is based on both statute as well as Executive Order and 9 probably the document that we refer to most often is the 10 Memorandum of Understanding between FEMA and the Nuclear Regulatory Commission that was signed a couple of years ago. 11 It basically spells out what it is we are going to do versus what it is that you are going to do as far as emergency preparedness at fixed nuclear facilities and 5 14 other fuel cycle and material license holdess. 15 We also have a role that in radiological emergency i 16 preparedness that incl.udes the Department of Defense and the 17 Department of Energy facilities as well as working with you l a relationship with transportation incidents. l 18 COMMISSIONER AHEARNE: Lee, could I ask a question? d 19 MR. THOMAS: Certainly. j 20 ~ 8 COMMISSIONER AHEARNE: It doesn't relate to our j responsibilities, but since you have mentioned it here l 21 i 22 just out of curiosity, what kind of interaction are you able 23 to work with respect to the state and local governments for 00D facilities? Are you able to get an equivaient level 24 (- of detail on D0D's facilities and procedures to mesh with the i g state and local governments? ~

5 1 MR. THOMAS: The answer to the question is yes and 2 no. It' depends on where we are working and with which state jg. 3 and local. We have been working quite actively with the 4 Department of Defense to develop the kind of guidance that j was developed jointly with you for fixed nuclear facilities. 5 We feel that we are coming to a point where we 6 will be able to proceed with states to develop the kind of 7 planning that we are doing around fixed nuclear facilities. 8 We are in the final stages of developing the 9 Federal Radiological Emergency Response Plan, the generi~c 10 plan for federal agencies, that includes not only the fixed nuclear facilities but Department of Defense facilities.and 33 Department of Energy facilities. I would say that as far as timing is concerned, 13 . ?[; the D0D facility planning and the offsite planning and our ~ 14 involvement with state and locals is a year to a year and 15 half behind where we were, for instance, with yours. There 16 has been a traditional direct relationship between the '{ 17 military site commander and the.particular local unit of g vernment and state government that-insures a response 18 >l capability. '~ .j 19 What we have done is to come in, I think, and s 'I 20 a begun to broaden that as we did, for. instance, with your ,1 ( j-facilities. I think we are making significant progress there. 21. 22 ' COMMISSIONER AHEARNE: Is this the same situation for 23 the DOE facilit es? MR. 'JHOMAS : 00E; I would say, then trails along 2, - (55 behind D0D. Basically we-have looked at them as far as r 25 priority and. as far as potentia'l hazard is concerned. ~

6 I COMMISSI,0NER AHEARNE: Thank you. gg 2 (SLIDE.) e= 3 MR. THOMAS: The process we use then for evaluation of offsite preparedness requires interaction with state and 4 local governments. Clearly it is the responsibility of state and locas governments to be prepared. It is not FEMA's 6 responsibility. It is not your responsibility. What our 7 responsibility is is to assist them in this preparedness 8 effort. 9 We do that by providing guidance documents, the 10 "350" process, the 0654 criteria and other guidance documents to them as what will be the standards as far as preparedness is concerned that we are going to look at jointly. 12 We assist them in plan development. That often 13 (( means people in our regional Offices, our technical contract- ~ 14 ors, a'ctually working with the state or local unit of 15 government in developing that plan. 1e We rev.iew those draft plans. Now our review is both review by our own people, contract technical assistance, 37 e as well as coordinating a federal agency review at a regional '8 1 level through '.he regional assistance committees. i 19 l-We also coordinate multi-state plans and 20 preparedness where there are multi-state concerns to insure ,J; 21 that there is consistency between those state planr. E' 22 We also evaluate exercises and coordinate the 1 23 - other federal agencies in that evaluation. The exercises, as you know, are full field exercises where we have federal f5h monitors that actually observe the exercise. A critique is

== 2S developed. I

7 L. Iv 1 l We also participate in public meetings that are gg-2 required _and are held at each one of the~ facilities, often w 3 several in.the vicinity-of a facility. .4 CHAIRMAN PALLADIN0: Lee, with regard to plans, since state and local people come and go and there are changes due to election.s and changes in career plans on the part of 6 people, do the plans have facilities whereby there is reorienta-7 tion or indoctrination of the individuals that come in and 8 play a part on these plans? 9 MR. THOMAS: One of the components that we look at 10 and one of the planning aspects deals with training and education of the personnel that would be required to respond 11 or to direct a response. So as a part of that plan that the state or the locals lay out how they have a continuing training ((; program for their personnel. ~ 14 CHAIRMAN PALLADINO: Who monitors that? 15 MR. THOMAS: We monitor it as far as that state plan 16 is concerned, a continuing review of that plan both in their S l 17 exercises and primarily the exercise that is held as to another 18 - at how they are carrying out that part of the plan. I I-COMMISSIONER AHEARNE: To pick up the same point j ~19 g I was discussing.with you the last time you were here, you I 20 a have-here, " Requires interaction with state and local govern-21 ments." Perhaps I had a misimpression last time. The impres-22 sion I got from the last meeting was that.your primary inter-22 action was with the state and then you counted heavily on the state 'to interact with the-local government. 24 dis - MR. THOMAS: .I would say generally that is true. 2 not in every case, however. .It depends on the-organizational

s - 8 s. 'l responsibilities -as they are laid out in che particular state. 2 Our process does identify the governor as the chief official-3 of the. state who we look to for planning as well as the implementation responsibilities in that state and' we work throug h ~ 4 the governor's designated representative. Now we do require a 5 state-as well as local site specific annexes in a plant. We do look to the state as' the group we look to develop tha.t. 7 In a number of cases we have found that we have to 8 actively get involved in providing assistance to the state ,g and through the. state to the local units of government involved. 10 In some cases we have found that we may end up working more t with the local unit of government than the state. 11 For instance, if the organization of emergency responsi t 12 around a facility in a state is more centered at a local level 13 j f _. than a state level, so it depends on how th'ey have organized r= = 14 the authorities within that state as to how much of a role ~ the state plays and how much a local plays in developing the 15 actual plan and the exercise. 16 But in the final analysis, you are right. It is'the l I'- 17 state and it is the governor that we look to as far as the 18 ig ] :- 2rimary official that we deal with. j 19 COMMISSIONER AHEARNE: Is it correct then that when 20 ~ nou deal with the local governments, it is a second step. And I'$ 21

he first step is you have gone through the state.

'I 22 MR. THOMAS: Th'at's correct. COMMISSIONER AHEARNE: So dealings with the local 23 lovernment in a sense is always through the state? 24 MR. THOMAS: It is through the state and I don't want-5sf a to use the word.always because that.means forever and ever or .,g -,y or p -= ge -y m m'er -s .Pr-e.w-t. wm e e--m ma v--w m-m' m-m. -+-ee c --

9 4 1 always we do it. It may well be that in a particular state

(g if we find that the state does not seem to be able to develop 2

3 the relationship with the local unit of government to insure 4 an integrated plan or to compensate for that local unit of government's say lack of participation in planning, we may 3 well then deal.directly with the local unit of government 6 but it is with the knowledge of the state. 7 COMMISSIONER AHEARNE: Thank you. 8 (SLIDE.) 9 MR. THOMAS: To continue then as far as the process 10 we use for review, we have published a process, the "350" process, which you have heard about I am sure for quite a 11 while and it does lay out a sequence of events or a process that we go through. 13 C For instance, the first part we talk about is the ~ 14 governor requesting "350" plan approval. That actually 15 occurs after an awful lot of interaction has gone on between 16 our regional offices and the state and locals that are a k 17 participating because we get involved in r,eviewing draf t plans and assisting them in developing those plans and then 18 i often correcting deficiencies that have been noted in draf t f 19 g plans. 20 But in the final analysis, the governor does make h an official request that we review their offsite plan and that 21 Li 22 we approve their plan. There is a requirement for public 23 meetings as a part of that planning process. l Those public meetings may be held _, for instance, 24 h one public meeting -- it depends on generally the geography and the population as to how many public meetings need to be held

'10 s I to insure that the public surrounding that particular plant 2 ((} have an opportunity to comment on the plan or to raise issues 3 that they feel need to be addressed. 4 CHAIRMAN PALLADINO: They do have the opportunity 5 for input at that time? MR. THOMAS: Yes, at that time. It is a public 6 meeting that we participate in. It is a public meeting that 7 is held by the state and the locals and generally if you can 8 picture a panel of federal, state and local people and gener-8 ally utility people. 10 Having conducted three or four of those public 11 meetings, they are generally fairly lively with quite a bit f discussion. Generally the public that is there has 12 reviewed plans. Particularly with new plants, intervenors ([h participate very actively in the public meetings. They have 14 a very good knowledge of the plan itself and raise numerous 15 issues. 16 There is a part of the process that I would like to I-17 emphasis and that is when we review the plans whether it is is the formal plan review or otherwise, there is the regional } assistance committee approach both at a regional level and a j federal l evel that we coordinate and that is the other 20 } federal agencies other than FEMA participating and commenting on that plan review, Department of Energy, HHS, NRC," Department l' 22 of Agriculture, EPA -- the other federal agencies take an i !~ 23 active part. 24 As a matter of fact, we report to Congress jointly _((I with you on a monthly and now quarterly basis and in those 25 I reports we note whether we are having problems as far.as other J

3- - 11 . 1 federal agencies participating. jgg 2 But their expertise is drawn upon both as far as

e=

plan review and then later on when I mention exercises in l 3 'the next one, they also participate in the exercise as federal . observers, generally reviewing that part of.the exercise or 5-that part of the plan that they have expertise in. 6 COMMISSIONER GILINSKY: How big a thing is this 7 pl an ? 8 MR. THOMAS: The plan is a fairly large document. g-You are talking about something like this. It has the details based on 16 planning' standards as far as emergency preparedness 10 is concerned. It is a detailed document. [ 11 4 COMMISSIONER GILINSKY:. About like that notebook; 12 i MR. THOMAS: The exercises is a major part of the '3 process prior to the completion of the "350" process. . =- w== ~ 14 CHAIRMAN PALLADIN0: Let me ask a follow-up question 15 on that. Would that plan indicate names of individuals to be j contacted in the event of certain circumstances? 16 What is behind my question is how is that maintained current? 17 .I MR. THOMAS: Vern, do you want to respond? 18

b.

MR. ADLER: The answer is yes on both counts, i j 19 ' f CHAIRMAN PALLADINO: How do you maintain it currently? ; i j. . 20 MR. ADLER: As names have changed the state and. local l

,t*

21 governments are expected to put in revision pages and to . i. i I inform the FEMA region. ~ [ 22 MR. THOMAS: A part of the plan is.the revision g process. 24 gn-COMMISSIONER'GILINSKY: It is a looseleaf notebook? l p =- 25 1Hl.. THOMAS : Yes. .im. .m. .,--,_r r,- .. +y, cw.y

12 4 1 CHAIRMAN PALLADINO: How many people have it? What

=k 2

I am thinking of is you have this widely distributed, how w 3 are we assured that the names get changed as appropriate? COMMISSIONER ASSELSTINE: That is one of the things 4 you test in your exercise, isn't it, the notification of people. 8 That is a major part of the test is MR. THOMAS: 7 the notification process. 8 CHAIRMAN PALLADINO: Okay. 9 COMMISSIONER GILINSKY: To what extent of those 10 participating at the public meeting had a chance to look at the plan? MR. THOMAS: The plans are made available at various 12 points in, for instance, a county for the public to review

=

and look at. For instance, in a public meeting that I f 14 conducted, the plan had been available at eight or ten 15 different locations in the county and the public had reviewed 16 it. [ COMMISSIONER AHEARNE: It is similar to the EIS-type g 8-public meetings and other public meetings that are held I 18 g c gather. j 19 CHAIRMAN PALLADINO: Did'you have a question? 20 i COMMISSIONER AHEARNE: I had a follow-up question. 21 to. Mr. Adler on the issue of the pages being available. Would -s* 22 the normal system be tha't there would be several hundreds of l those books in a state? 23 l MR. ADLER: I would doubt that there would be that l 24 lf5b many.: I can't tell you precisely how many but expect all of 'r 25 i I =.

13 1 the significant responders to have access to those. g3 2 COMMISSIONER AHEARNE: Who controls the book in the m= .3 following sense? If you publish a regulation and you have updated pages that you are trying to put into that regulation, let's say a manual in an agency, someone has a record of who 5 are the people who have to take action on the basis of that 6 manual and they then get distributed, all these changed pages. 7 Is there a similar person or office in each state and is in a control of those books? ,9 MR. THOMAS: It is the designated state agency. that the governor has designated and in most cases that is 10 the state emergency service agency, the agency that submits s 11 ) the plan to us. 12 COMMISSIONER AHEARNE: And they are the ones that I* you hold responsible for keeping the plan updated? 5-1 MR. THOMAS: Yes, and the specific annexes if they 15 are county annexes. So the exercise is a major part of the 16 process and that,is where you are, in fact, assessing the { preparedness capability of state and locals and those 2 exercises may be a day or two day or full scale exercises 18 in the field where the players are actually going through a j 19 scenario that they are not familiar with to test their capabil-l 20 ity to implement that plan. f 21 We then will receive a plan review exercise critique 22 into FEMA headquarters where the federal radiological prepared-ness coordinati'ng committee which is kind of a counterpart 23 to the RAC committee at a regional level will review those ggy plans and again make comments on them to insure that if there "r 25 are any deficiencies noted we have gone back and given the

14 l 1 state an opportunity to correct those. 2 l(jy In the final analysis we give you when we complete 3 that "350" review process, we give you, NRC, a finding from 4 me on that particular plan. I will note in a minute how many 5 we have completed in that process and kind of where we stand on that whole thing. CHAIRMAN PALLADINO: Where in the process do you 7 give us that assessment, after FEMA approves the plan? 8 MR. THOMAS: That's correct, basically after we 8 have approved that plan or disapproved that plan we send a 10 letter to the governor. We send a letter to you. We publish 11 in the Federal Register our findings on that formal plan review. 12 COMMISSIONER AHEARNE: Could you say a word about $hh the relative approval authority of the regional administrator 14 of FEMA and FEMA headquarters? 15 MR. THOMAS: I had the approval authority in 16 headquarters and -it is not delegated to the regional director. 8 17 The regional director provides findings and regional review 18 on that to me and I am the one who has to approve or disapprove the plan. 19 y COMMISSIONER AHEARNE: Do you have a separate group 20 j that then reviews the regional administrator's recommendations? 21 l MR. THOMAS: Yes, that is the Federal Radrological 22 Preparedness Coordinating Committee chaired by Dick Krimm and 23 Dick's staff reviews the plan as well as other federal agencies 24 that review the plan. It is a basic tiered system with 5k! reviews at each step. 25 COMMISSIONER AHEARNE: So in theory then, you might

~ l 15 I reach a different ennelusion than the regional administra' tor? - q=3 2 MR. THOMAS: That's correct. he= COMMISSIONER AHEARNE: Have you? 3 MR. THOMAS: We have reached different conclusions 4 at different points and gone back for review, revision and 5 update. 6 (SLIDE.) 7 MR. THOMAS: This is the formal "350" review process 8 and let me point out a couple of other places that we interact . 9 with you other than this formal process. That is a fairl.y l lengthy one. It goes through a number of steps. You have a 10 need for and have asked us for information other than that 11 which we provide yea at the conclusion of that "35a" process 12 and often, for inst?.nce, when I have been over here it has 13' been to talk with y,u about findings that we have made other =- -g 14 than that final "3t0" approval or disapproval of a plan. 15 For instance, the interim findings are status to reports. You wil1 ask us for an interim finding. What is f the status of Indian Point? Or where do we stand on any ,7 3I other utility? We will give you a status report then of 18 g s where we are in the "350" process at that plant or include j 19 7 or give you interim findings of what is the status of l 20-preparedness. 21 It is important to note that it depends tq a large 22 extent where we are~in that entire "350" process as to the level of detail' that you will get from us as far as interim 23 - findings. You may only get a status report and that is we have fjh ~ just begun working with this state and this local on this

== 25 to be developed plan and so the status is we are at a very-early ye ~ q +4hu 1.- y--,e-- g -.,-==.--a -p,- r--w W--

16 I stage of review of their capability. Or you may get a fairly 2 detailed finding because we are far over into it and have done g=-a sa detailed reviews of draft plans or we have had full scale 3 exercises and we have critiques of exercises. 4 So interim findings and status reports is a major 5 interaction that we have. Supplemental interim findings. which 6 are updating or additional information that you asked.for 7 over and above what we originally gave you. Yo.ur licensing 8 board here is a major interaction point between us. Our .9 people participate at a regional level and our headquarters often times as expert witnesses in those hearings testifying 10 to the status of offsite preparedness. COMMISSIONER GILINSKY: What is their role? Are 12 they participating as witnesses 'for one of the parties, for I the staff or what? a=- ug 14 MR. THOMAS: They are called by the Commission as 15 expert witnesses to testify on offsite preparedness. COMMISS10NER GILINSKY: 16 Are they called by the Board or by the staff or what? g MR. ADLER: The staff. We support your staff in 18 5 that hearing. You are the party. j 19 COMMISSIONER GILINSKY: We are not the party. We are [ 20 the judges. Aj 21 MR. ADLER: I am sorry. The staff is the party. 22 COMMISSIONER GILINSKY: I wonder if that is the right way to do it. I wonder if you ought not to be witnesses 23 appearing and called by the Board presenting your views. fgh MR. THOMAS: Basically, that, in fact, is the way 25 the witnesses. appear and present theiy views to the Board and

17 -l 1 are examined by both sides. There they are to testify as to Ik ~ the s tatus o f -- 3 COMMISSIONER GILINSKY: I understand that. I wonder 1 4 if you wouldn't be more comfortable being called simply as 5 a witness.by the Board. to present your findings rather than appearing in the guis_e of a witness for one of the parties .that-has' a specific view on the license? 7 It is something that you might think about. 8' MR. TH MAS : Yes. CHAIRMAN PALI.ADINO: I am not sure that it woul'd L 10 make all that much difference, but it might. 11 MR. THOMAS: I am not either. It is a process that our General Counsel's office largely directs but we can discuss 12 it with them. 13 h COMMISSIONER GILINSKY: I would suggest that you 14 turn that over in your mind. MR. THOMAS: All right. 16 CHAIRMAN PALLADINO: In this testimony provided to g the licensing board, is there coordination between the field 17 18 People that might be testifying and the headquarters people? el } MR. THOMAS: Yes, there is.

'i CHAIRMAN PALLADINO:

So you wouldn't be saying one lj 20 L thing and they be saying another? ! I 21 8 MR. THOMAS: No. Generally and I should make this il 22 - l point, on your hearings in a m'ajority of the cases those 23 hearings are held early in your process which. turns out to be l l. 24 early in our process. COMMISSIONER'AHEARNE: Very early. 25 MR. THOMAS: Very early in our process', and you often

18 I find that we are early in that "350" process as I mentioned

jgg 2

to you. -So as far as the headquarters interaction, we more w= 3 than likely have not in a number of those cases ever seen a plan. So the people who testify and the primary point 4 people are our regional people. Now if there are questions 5 about particular planning standards or if they want to go 6 into more depth of the basis of this, we often will supplement 7 that with a headquarters person who goes out. 8 It just depends on what the situation is. As a 9 matter of fact one of the problems we have and I don't know if you would call it a problem or an issue is the fact that to we are called to testify on offsite preparedness generally very early in a process, the "350" process. 12 The reason for that is because we are working again 13 cr-with state and local governments. The state and local govern-

== 14 ments view of when they need to have a plan completed, when 15 they need to be prepared to exercise, is generally gauged on 16 the operation date, the date that they are anticipating that f the utility will be operational as opposed to when your g hearing is going to be held on recommendations as to whether 18 y c they should be licensed or not. j 19 So there is somewhat of a disconnect as far as that 20 i hearing and what they are looking at versus the state and 'd locals and when they are viewing a need to'$ ave a capability. 21 22 Of ten times it is v'ery e'arly in the process. COMMISSIONER AHEARNE: And we have been struggling a 23 with trying to make some modification to try to mesh those two jf; together. ,e 25 MR. THOMAS: Yes.

19 1 COMMISSIONER GILINSKY: Just to return to that~ point, gga 2 it seems to me that you ought to be coming in as I think you u? thought you were as an independent witness giving your vie'ws 3 n the state of emergency prepa' redness that is your respons'i-4 bility rather than being part of the team that is there to 5 bring home the_ license. 6 COMMISSIONER AHEARNE: I would point out, Vic, that 7 we have explicitly set it up that they are different because 8 their testimony is treated as a rebuttable presumption which ,9 is different than anybody else's testimony. COMMISSIONER GILINSKY: Nevertheless,.I gather they to are there as part of the staff team. 11 CHAIRMAN PALLADIN0: I wonder if that might not be 12 worth looking into separately and get our legal peopl e 's

51 opinion on what their status is.

T 14 COMMISSIONER GILINSKY: I think that would be a good 15 idea. MR. THOMAS: Okay. 16 I (SLIDE.) j 17 MR. THOMAS: So those are the other. areas where we 18 '.g s interact with you and actually we more routinely interact with j 19 you than we do at the conclusionoof a full "350" plan approval. e:j 20 I want to make a point about that "350" plan approval. I J T6 made it the other day when I was here and that is,,when we t 22 complete that whole process, we have reviewed the plan, we send over say an approval of a play to you, that doesn't mean 23 we are through or you are.through. It is a dynamic process [~. that continues. It is a continuing review of the relevance 'r 25 of that p'lan, the capability of state and locals to actually

_ _ = 20 1 implement that plan and there may well be and will be changes, g particularly changes in administrations, changes in personali-2 3 ties that will impact on-that particular state or that particu-1ar local unit of government's ability to implement a plan. 4 So that letter of final approval of a plan merely means that ~ at that point in time, we have completed this full process. 6 We have approved it, but there is an ongoing review that has to continue. 8 So you may well see a problem at a plant come up a .9 year later, hey, last year we got an approval on this. I go make that point that it is a continuing process. (SLIDE.) HR. THOMAS: I want to talk a little bit now about 12 the specifics as far as plan review. I have already pointed 13 .g; out to you a couple of times that there are 16 major planning I 14 standards that we ase. Within that, there are 212 planning 15 elements that are reviewed. You see the ones that are related 18 to the state plan as well as the local pl an. t They are fairly detailed requirements that the states 37 and locals are looking at jointly with us and they know what 18 we are going to be looking at and that is a part of the j 19 g guidance document, the 0654 guidance document, that the state 20 a and locals work from. 21 COMMISSIONER AHEARNE: Your comment, Lee,."... one .j 22 on site planning standard not evaluated by FEMA," are there 23 on site planning standard -- MR. THOMAS: There is an on site planning standard. j[. COMMISSIONER AHEARNE: There are not other on site ,r. .a planning standards that you do evaluate?

21 l I MR. THOMAS: No. Of that, there is one we do not g f 2 evaluate. You evaluate. 3 COMMISSIONER AHEARNE: Right. l t MR. THOMAS: Again a public meeting requirement, l 4 a specific requirement, is looked at. (SLIDE.) i 6' MR. THOMAS: As far as exercise evaluation is j l 7 concerned, different from plan review, there are components e of all of the planning standards that are related to exercise 4 .9 evaluation. Again, when we have a full exercisa, it is a f D in joint exercise, state and locals and the utility exercise. l l you are reviewing the utility's capability. We and the other j 11 I federal agencies are coordinating a review of the state and i 12 local?s capability. 13 f . =e We da it jointly and of those 16 planning standards, t 14 there. are 74 planning elements that can be exercised at a. ) i 15 specific joint exercise. It depends on the scenario that is i 16 written as to whether every one of them is exercised or not. We evaluate; all off site exercises. As I have already 37 I indicated, it is generally participation ::y FEMA and our 18 i g staff, our regional office, our contractors, you _and other j 19 [ g federal agencies participate as federal observers. All plants licensed to operate are exercised .s 8 .I. \\ 21 , annually at present. I. have talked with you. about t4iat in the l 22 past and I will talk to you about it a little later on today. 23 All exercised involve a post exercise critique which~1s a public t critique where both you and. us give a critique to the state and [ 24 B local authorities and the utility as-to generally what we found. =-

25..

IWe ' follow ' that 'up 'with a ' detail ed critique which is -

22 1 notice of both positive and negative feelings about the exer-ggg 2 cise that was held.

s=

COMMISSIONER AHEARNE: Could I ask a question on 3 that? I don't know whether the agency has yet responded or has a chance to think about it, but on September 14th on behalf 5 of the Commission I sent a letter to the Director of FEMA and 6 the issue I was raising on behalf of the Commission was could i 7 FEMA hold a public meeting following an exercise'.- You had 8 earlier pointed out the value of having public participation ,e in the planning process and you pointed out you held public meetings as part of the plan. to What we are proposing that you consider is holding a public meeting af ter the exercise. 12 MR. THOMAS: There is a public critique after the I exercise. =' 14 COMMISSIONER AHEARNE: I understand that. 15 MR. THOMAS: I haven't seen your letter but we will be looking at that in responding to you, 16 CHAIRMAN PALLADINO: What do you mean that there is g a public critique? 18 MR. THOMAS: In other words, the critique is held j 19 in a public forum. j l 20 CHAIRMAN PALLADINO: Does the public have a chance Jl 21 to interact? I E MR. THOMAS: No. 22 COMMISSIONER AHEARNE: That was the issue that I 23 wanted addressed. 24 fpg COMMISSIONER ASSELSTINE: Lee, before you leave the =- 25 exercises could you speak for a moment about the role of partial

23 1 exercises as opposed to the full scale exercise, what you 2 want to accomplish there, what dictates 'the selection of a 3 partial exercise versus the full scale exercise? MR. THOMAS: There are two levels of partial 4 exercist. One is partial as to the parties, that is, whether is the state fully playing or whether it is the locals playing 6 or whether it is both. So there are requirements that while 7 the utility and the locals of the plant have to exercise a annually, that if there are multiple plants in a state, the .9 state actually does not exercise with every plant annually 10 so partial in that sense there are some differences there. But partial in the sense, where I come from and where I think we should exercise a good deal of flexibility is partial in the sense of the 74 elements that can be g exercised, which ones should we home in on. Should we have 14 based on last year's exercise, we have identified a number 15 of deficiencies, can we now home in on that with a partial 16 exercise as oppos.ed to again exercising the full plan when { we have reasonable assurance that we continue on a number g I of those elements have a good capabil_ity, let's home in and 18 g have a corrective exercise on a part to test that part. 3 j 19 So I do think that we need to explore that and look e:j 20 at that as an option and that is to go to more of that kind Jj 21 of partial exercise on an off year and a full exercise every E 22 other year. We have tal'ked about that before. CHAIRMAN PALLADINO: When you have a full exercise 23 how do you proceed? Do you, describe some scenario of events? g MR. THOMAS: Let me throw this next slide up as an =- 25 example, t'he Vermont Yankee Exercise.

24 1 (SLIDE.) MR. THOMAS: An exercise is a major event for the

g 2

state. It is not soaething that throw off in a couple of 3 weeks and have an exercise. It requires a tremendous amoun't 4 of planning to prepare for that exercise to insure that 5 the parties will be there, that both the federal observers 6 who are going to observe are all prepared, that the state and 7 local authorities are prepared for it, that a scenario is 8 written, that it is a realistic scenario and has been reviewed g by us. We need to feel comfortable with it and the e,xercise should be a full exercise that covers as many of the planning 11 elements as possible. 12 For instance, in Vermont Yankee, an exercise that 13 was held in February, you will see that it required three am ~ 14 state agencies -- I metn three states, Vermont, Massachusetts 15 New Hampshire and included 32 state agencies,16 local units f g vernment participated. That is a large number of people 16 I who participate in the field during that exercise and in a g 17 number of the exercises, you will find that the governor 18 participates directing operations or participating in. an l' emergency operating center during the majority of the exercise l 20 or participates by making decisions during that exercise. 21 We try to play it as a real event. They try to play 3 E it as a real event with the real actors who would participate 22 in a real event taking part in it. As far as the federal observers are concerned, that one is an example. We had 38 24 gg_ total,14 of our persoi.nel largely out of our regional office, 7~ 25 in that case,.for instance, the Boston regional office. They may be supplemented by people in our other regions depending on - m.. . m. -s

25 ~ 1 s I what the need is. g=3 2 Contract personnel, we have a major c'ntract with

e=

i 3 Argonne National Laboratories to provide manpower to us j as far as review of exercises, so we had 15 contract personnel. Nine people from other federal agencies including FCC were 5 participating and serving in the role of federa observers. 6 This is an example of a New England exercise. 7 In New England there is obviously multi-state involvement l 8 in most of the exercises. As a matter of f act, multi-state 9 involvement is an issue in most of the exercises around the country that we have except in some of the larger states. l 10 COMMISSIONER AHEARNE: When you say, "is an issue," l 11 what do you mean? 12 MR. THOMAS: That more than one state will play 13 l and one of the things we are-looking at is the interaction =" mi c 14 between the state emergency operating centers, for instance, l 15 that they are operating jointly and that we don't have one 16 state going off a,nd taking a whole series of actions uncoor-I dinated with another state. I 17 CHAIRMAN PALLADINO: Lee, if you had an actual 18 event rather than an exercise, you wouldn't have the opportun-t j 19 ity for all the planning, what parts of the activity would = l 20 not take place? For example, I presume you wouldn't have J" 21 your contract personnel there to evaluate or would you? t e 22 MR. THOMAS: I'f we have an actual event, as you know there is an emergency response plan. As a matter of fact,. j 23 we are getting ready to hav.e our first exercise with you and 24 i the other federal agencies this year on the exercise of the ,e 25 federal plan as to the federal personnel that would be t

26 1 available to support. state and locals in an actual event.

%qg

-2 In that regard, we have an emergency response team ?. 3 out of our regional office and an emergency support team out of our headquarters that would participate in the field and in 4 headquarters to support state and locals in an actual event just as'you'had your teamt that go in to support the utility 6 in an actual event. 7 The other federal agencies have identified similar 8 personnel both region and headquarters who participate in .- 9 that. It may well be that in an actual event we would call 10 on some of our contract personnel to supplement ours, but I i think in an actual event you would find, for instance, a significant amount of additional personnel from other 12 federal agencies that would be available to participate. 13 ,-]; 1 B CHAIRMAN PALLADINO: What I guess I was getting at 14 was'do you think our exercises really get to a representation '15 of what we would actually face in an emergency? 16 MR. THOMAS: At a state and local level, I think they do. I think we have not exercised fully the federal 37 I participation. We have served more the role of the monitoring 18 and critiquer of the state and local exercise in this regard g 19 g and I think we are developing and are. going to be-gin exercising i 20 now the federal participation in an operational role, the 4 2? one coming up, for instance, the October 5th headquarters 22 exercise that is coming up as I see it is a major event of the 23 federal agencies which is an exercise of the-federal agencies in a response mode as opposed to any kind-of monitoring mode. fEs Then we have 'a full scale federal agency response -T 25 exercise scheduled for the spring. Those are major events. \\ ,a-

27 COMMISSIONER ASSELSTINE: Would you say, Lee, that 2 g probably at least at the state and local' level the performance 3 during the exercises is probably going to be at the high 4 scale since everyone is so warned ahead of time that it is j 5 going to happen and all of the people that are going to be the key players clearly would be in town and would be available ~ 6 and in all probability have looked at their materials. j 7 MR. THOMAS: Absolutely. I think it is a realistic 8 l exercise. I know the ones that I participated in have been j 8 very realistic. They do strain not'only resources but i lo decision making as well. l 11 CHAIRMAN PALLADINO: I guess my concern is associated j with the fact that when events take place not everybody is u exactly where they ought to be and I am not sure how represen-b tative the exercise is of what we might face on the average. 14 MR. THOMAS: Fortunately we have had relatively few - 15 incidents where we have had to deploy. I guess Ginna is an [ l 16 example of where we did and I think the actual reaction there 1 ,g 17 as compared to the exercise there was fairly consistent. COMMISSIONER AHEARNE: Certainly what we found in i 18 i other areas of the government, the military primarily, is when J you go through a structured exercise, you go through it enough 20 a times although any exact instant isn't going to track and l 8' 21 ~ some of the~ people are not going to be the ones thaf went r 22 through the_ exercise, as long as enough of the people have i 23 gone through~the concept of working.together and meshing j - 24' these various parts, it works. f MR.-THOMAS: -It does. [ y - 25 COMMISSIONER AHEARNE: It is significantly better = 6

28 1 than if you had not gone through them. gg 2 MR. THOMAS: The training that comes out of it is .ee 3 the major benefit. CHAIRMAN PALLADINO: I am not against the exercise. 4 I was just trying to see how representative it.is to what 5 we might actually face. 6 (SLIDE.) i 7 HR. T:*1 MAS: The next slide if we look. at plan review 8 we look at exercises as to where we are at this point in time l .9 with both the operating reactors as well as the "to-be-licensed facilities." go Fifty-three sites now and I am not talking about 11 reactors, I am talking about sites, licensed to operate -- of 12 those, we have completed the full "350" review process for ggg 12 of those. In other words, you have gotten the final formal document from us on 12. The other 41 have plans under 15 review. You can see the number of states and local governments to involved. Now we have completed "1st" round exercises at all 37 53 of the sites that are licensed to operate. Of those, we i 18 g have also completed "2nd" round exercises at 15 of them. Four j 19 of.them we have already had the "3rd" round exercise. e 20 i COMMISSIONER AHEARNE: What is your definition of 2 21 a round? 'i E 22 MR. THOMAS: It is just an exercise. It means that l l at four sites w'e have had three full scale exercises in the 23 context of the exercise I was-talking about, the "350", which' is a full scale state and local exercise. r 25 Of the 31 sites, NTOL ' sites -14 sites have plans

29 1 undar review at this point in time. Three of those have y=3 2 completed full exercises. None of them.has completed the -*e full "350" process which is basically to be expected at this 3 point. COMMISSIONER AHEARNE: When you have your 53, 15 5 and 4, are any of those 15 and 4 as a result of the "1st" 6 round exarcise'not having been sufficiently satisfactory and 7 so you had to in less than a year in between go back and 8 have to have a second round? g MR. THOMAS: Require that there be a second exercise. MR. ADLER: I don't think so. 3g MR. THOMAS: In a number of cases we find that we 11 had the second exercise in less than a year not necessarily 12 because we said they had to have it in less than a year, but 13 it was good to have it in less than a year particularly in =s u=a ~~ 14 some of these cases. 15 The sites that are planned, no FEMA activity at this point in time. At the bottom, I indicated the 13 ASLB -16 hearings that we have participated in, eight of them having g 17 4 been completed and five of them remaining open. (SLIDE.) j 19 MR. THOMAS: Projecting for fiscal year 1983 when ij 20 we look at work load, we are projecting completing 23 additional 21 "350". site specific approvals including 18 states' and 91 locals. I~ 22 Draf t site specific plans, we are anticipating.13 additional ones coming through as far as sites as concerned. g Exercises, we pro. ject 63 sites will be exercised 24

g this year, more than one a week.

As you can see, we are heavy ,e 25 into the "2nd" round of exercises, "2nd" and "3rd" rounds of

30 1 exercises at the utilities and we are anticipating participa-gg 2 ting in nine new hearings, of course, and continue to partici-w 3 pate in the five that are still open. COMMISSIONER ASSELSTINE: Lee, when do you expect 4 to have completed "350", approvals for all operating reactor 5 sites? How far down the road is it? MR. THOMAS: Dick is saying that our plan is to try 7 to get all of them finished by the end of this year. So I B would say that you are talking about shortly after t c end 9 of fiscal year '83. I could give you a specific projection on that. to COMMISSIONER ASSELSTINE: In any event, no later than the middle of fiscal year 1984. 12 MR. THOMAS: We were trying to look at getting 5-all of them approved in fiscal year 1983, but I can get

== 14 back with you a specific follow-up if you want on when we 15 anticipate all of the completion. 16 COMMISSIONER ASSELSTINE: Let me ask you another question on that, too. If there is some question about the ability to complete them all in '83,.is that a question of 18 g c resources? j 19 MR. THOMAS: I think it is more a question of aj 20 processes and where the s tates stand and where the local A" 21 stands as far as the plan and the exercise. A lot of it 22 depends as well or is driven by where that plant was as far 1 as actually going into operation and where the states and 23 locals were as far as that plan is concerned. 24 ggs COMMISSIONER AHEARNE: When you say " process" as . =- 25 opposed to " resources," does that mean in many cases though

31 1 it is driven by state and local resources? g3 2 MR. THOMAS: Yes. For instance, say you take the = 3 state of Illinois that has five aperating plants and is anticipating two more, five sites and anticipating two more. state and local resources obviously plays a big part in 5 how fast they can move through that process of their plants. COMMISSIONER ASSELSTINE: But at least it is not 7 a question of resou'eces on the federal side either in your 8 agency or in the people from other agencies including our 9 own to support those review teams. MR. THOMAS: We have had a problem with resources 10 in our agency. There is no question about that. When I 11 first came there, I looked at the work that was to be done 12 and the resources we had and I didn't feel like it was 13 possible to complete the work in a timely fashion and the 14 agency submitted a supplemental budget request to Congress 15 which Congress didn't fund for additional personnel. 16 We also went out and I met with Department of I Energy personnel and we were able to work out a cooperative g 17 agreement with them for major contract support and I will 18 talk a little bit about those things in a minute. j 19 But I do feel that if we are able to receive the ,,:i 20 funding from Congress for fiscal year 1983 that we requested -A l 21 which includes an additional 30 positions and continue the 22 contract support which we have now that it will not be a matter of us not having the resources. 23 CHAIRMAN PALLADIN.0: Lee, as long as we are back 24 gg3 at this question of getting the licensed plants taken care of, CEr 25 you had 53 sites licensed to operate and you have 53 "1st" round

32 1 exercises, does that imply that every one of these sites had 2 an exercise? 3 MR. THOMAS: Yes. CHAIRMAN PALLADIN0: Even though the plans were not 4 all complete? MR. THOMAS: That is correct. 6 CHAIRMAN PALLADINO: You do have the exercises before the plans are completed? 8 MR. THOMAS: Before the final approval of the plan 9 is completed, the plan is in some draf t stage when they hold the exercise. As a matter of fact, a number of the states like to to hold the exercise after we have reviewed a draf t plan and make corrections. They have an exercise and they may make 12 further corrections to their final plan based on that exercise. 13 But, yes, every one of the 53 sites -- we were 14 shooting for the date, as you know,1 July and there were a 15 few that were exercises right after that, but basically 16 they have all been completed. f (SLIDE.) 37 MR. THOMAS: Now, generic deficiencies. I talked 18 g in the beginning of what we mean by that. Let me say again j 19 g that what we mean by that is as we have looked at plans in 20 9 of the 16 planning standards on a fairly routine basis, Aj 21 we find problem areas when we review those plans, problems 22 that the states have to go back and correct, problems that are a result of resources that have to be developed or 23 procurred, but I wanted to provide you with where the bigger problem areas are as far as state and locals are concerned in (- 25 developing their plans.

33 i a 1 Again, as I said in the beginning, as you look at a i 2 <f-plan and as you make a bottom line review of whether there are q ) 3 significant; deficiencies in that whole plan, you have to put 4 each deficiency in the context of the total plan. You can't just single it out and say that as a result of this, the 5-capability doesn't exist or the plan is deficient. { 6 So if you would think about that as I talk a little 7 through these, there are niae of them. The first one is l 8 assignment of responsibility, one that we find is a problem 9 area and that is, just the formal agreements between state i 10 and locals and between states as'to whom does what, when they do it, who has organizational responsibilities. You have [ 33 t seen that in some recent ev2nts. 12 i-It is a problem that we note. It is an intergovern-13 mental problem that takes time for states and localities to [ work through. 15 Emergency response support and resources,- here again 16 lack of written agreements, formal understanding, with I h 17 supporting agencies whether it is Red Cross or other agencies, o - - that would provide support, say, for sheltering of whatever 3g ' E: that we require formal agreements between those agencies. We -j f 19 note that as a problem of ten times. d l $' 20 3 Notification methods and procedures and I will come 4 j back: to this in just a.little while, but prompt notification 21 I 22'

apability, the whole alert and notification capability ~ is one l-23 that.is.an area that is noted often times as far as problems i

k 24 . ire concerned, and we.have undertaken activity over. the last L l fa fear to develop more specitic guidance, more specific 25 l standards.for the state and -locals and utilities. as -far as. the n s ...,.-.7

34 alert and notification system is concerned. We have a major 2 t contractor that has been working with us in the development of that. As a matter of fact, during the next two months, we 4 will be putting into final form that guidance and then testing 5 that guidance at three specific site locations for alert and notification systems. 6 Public education and information is a fourth area 7 where we note problems of ten times and we talked about it the 8 other day and that is the specific' capability for public 9 education in the emergency planning zone, rumor control 10 procedures, just procedures in place for insuring that the 11 public is aware of what is to be done, and if there is an 12 incident how do they get information, how do they get accurate information and correct inaccurate information. 13 COMMISSIONER AHEARNE: Do you have any details in 14 your criteria with respect to non-English speaking people 15 with public documents? 16 MR. ADLER: No, we don't. The judgment has to be ,i made as to whether a broad enough distribution of intelligible 17 18 messages is made and if there is a segment of the population j gg that is non-English speaking, that has to be taken into b consideration. [ 3 20 ) CHAIRMAN PALLADIN0: But that is in your guidance 21 i d6cument -- MR. THOMAS: That you have to address that issue. 1 23 CHAIRMAN PALLADINO: --that you have to address 24 the issue. 25 MR. THOMAS: Yes. COMMISSIONER AHEARNE: You don't have any criteria

35 I that says that if "X" percent of the population do not speak ,e - 2 English but speak a specific language, then the information u. 3 must be available in that language? MR. ADLER: No. 4 CHAIRMAN PALLADINO: And where there are many different ethnic groups, do you address -the issue of all the 6 ethnic groups? MR. THOMAS: It is addressed in the context of the 8 guidance that we just went through. It is a judgmental call 9 as to how that is done as we review it and how if there are to a large number of different ethnic groups and foreign speaking individuals, how all of them are addressed. The guidance is g that they have to address the issue. 12 COMMISSIONER AHEARNE: Do any of you know from the 13 experience you have had with the plans, are any of the public r documents or the' broadcast notices that currently exist done 15 in more than English. 16 MR. ADLER: I know of none, but they may very well 17 exist where the state has perhaps a large Spanish speaking e population, they may have elected to do that and put it in 18 g C the state plan. We can find out. j 19 g COMMISSIONER AHEARNE: I would appreciate it if you l 20 could. Aj 21 CHAIRMAN PALLADIN0: I gather at Indian Point, for 22 example, that is a deficiency that was noted.that this 23 hadn't been developed. MR. THOMAS: It was a deficiency that they had not _ (-- addressed that issue and that is one of the deficiencies 25 they are dealing with.

36 (SLIDE.)

r 2

MR. THOMAS: Fifth was accident assessment and that 3 is the methods, the equipment and the expertise to make rapid 4 assessment of the hazard and that is the state and locals capability to do that independently, whether they have the 5 equipment and capability to actually ass'ess what the accident 6 is and the danger it poses. 7 Protective response -- a CHAIRMAN PALLADINO: You;used the word, " independent 1y 9 and I am not quite sure I know what you meant. Do you mean 10 that the state or the local people must be able to assess the action independently? 11 MR. THOMAS: One of the things we look at is the state authorities and inconjunction with them the local 13 authorities' ability to actually make judgment on what is the danger that exists and how they tie in with, for instance, 15 the utility as far as getting that information, but their 16 ability to actually make a decision. In otner words, their 17 radiological health unit at a state level, had they designated individuals with a capability to actually review data and make 1 18 decisions on the level of the accident as a part of the plan. j 19 g So we do look to the state to have the capability 2 20 8 to both interpret and make decisions. 4f .~ 21 CHAIRMAN PALLADIN0: I could see perhaps at the state 22 level, but it might be a problem at the local level. 23 MR. THOMAS: We don't require that in both cases they lave that capability. Again, we look to the state and ask what 24 .( is'the capability. Protective response, that is what kind of protective

37 - 1 ~ For instance, the decision response capability in fact exists.

m

2 process for administering radioprotective drugs, has their 3:

been identified criteria and a method for making a decision on the use of potassium iodide say for emergency workers or 4-for immobile ~ persons. 5 i 'We find that in plan reviews that this is of ten an 6 area where additional work needs to be done at a state level. 7 COMMISSIONER AHEARNE: Does FEMA have a position as 8 to whether or not there should be availability of potassium 9 iodide? MR. THOMAS: There is in the planning standard as a 10 part of protective response a requirement that for emergency workers and immobile persons that potassium iodide, that a 12 { process for administering potassium iodide be available. The l 13 response or the authority and requirement for actually doing 'e N that rests at a s' tate and local level. 15 COMMISSIONER AHEARNE: Would I interpret what you said,{ i '16 that FEMA requires there be a stock pile of potassium iodide { available? 37 s MR. THOMAS: We require tinat in that plan they identify !I 18 how they a'e going to procure and use it. s r j 19 i g Radiological exposure control -- basically how they r !- 1etermine that there is an exposure, what are the levels of .?; 21 exposure, the criteria used for making a determination as to wher ' 22 )eople should be moved out or moved in, particularly as far as emergency. workers we are talking about h'ere, but exposure control 23. rhis often gets back into the equipment issue that I noted under ?{- tecident assessment down under exposure control. 1 25 We often run into issues of available equipment, how i 1 3 ,n.

38 that equipment is distributed and how it is read and on what 2 {- basis it is read. 3 COMMISSIONER AHEARNE: Did you say. Lee, that under 4 that comes the chain of decision for requesting evacuation or recommending evacuation? MR. THOMAS: You would actually under those three 6 noted there is where you are looking at both the accident 7 assessment and then what kind of protective response is 8 required which may be a series of things. It could be 9 evacuation or it could be protective response of the indoor to window-closed / door-closed kind of thing or it could be a radioprntective drug. 3, COMMISSIONER AHEARNE: The decision network is 12 incorporated within those? 13 MR. THOMAS: Yes, and one of the things we are looking 14 at there is that decision network as far as protective response. 15 Medical and public health support is another one 16 that we often note that additional work has to be done. At 3j j7 times it relates to resources. Often times it relates to ~ 2 training, the ability of a public health hospital or other 18 O aesources to deal with contaminated individuals and that is one .j 19 g area that we deal with quite often. 2 20 8 Finally, radiological emergency response training -- l just specifically the training and we have already talked 21 22 about it earlier,.the requirement for a continual training 23 process for individuals who would either direct or participate 24 in an emergency response process is one that we often go back (l and deal with a state or locals on. .(SLIDE.)

39 1 MR. THOMAS: Now that related to plan review. As it =2 {" relates to exercise evaluation and you will see here again as 3 I have already indicated, there are a number of -- 4 CHAIRMAN PALLADINO: Can I ask a question? MR. THOMAS: Yes, sir. 5 CHAIRMAN PALLADINO: There are numbered deficiencies. 6 Are they all about equal frequency or are there some of them 7 that are encountered more than others? MR. THOMAS: Some are encountered more than others 9 but I don't have the specifics. Under guidance i gave to the 10 staff was is that in our plan reviews over the last two years I want to identify the ones that in our judgment seem to he 11 fairly general deficiencies that we see on a fairly routine basis as we look at plans. I did not give them a number cut 13 off, the ones that we felt were deficiencies that required a 14 good bit of work. 15 CHAIRMAN PALLADINO: But I gather these are frequent 16 enough that you fel t -- 17 MR. THOMAS: Yes, to bring to your attention. 2 CHAIRMAN PALLADINO: -- you should identify. I 18 MR. THOMAS: Yes. And there are also as you will j 19 y note in a minute frequent enough that we try to take specific 8 20 8 action in trying to assist state and locals. 21 As far as exercise is concerned, I have already 22 noted the notification methods and procedures under plan 23 review and the activities that we have underway-to try to assist state and locals and the utilities as far as alert and notifi-24 ( ation is concerned and the methods that we will use for ~ 3 ass'essing that capability..

40 Protective response. Again, we talked about that. 2 ( It comes out often times associated with that decision chain 3 and the ability to actually evacuate, for instance. As you 4 know in a recent example, for instance, the transportation 5 wouldn't have their own transportation. We find that in 6 exercises often times that comes up as a deficiency and that 7 is, it has been noted in a plan that there were specific 8 procedures, then we exercised and we find that there were a 9 couple of, gaps that had to be closed. Population distribution 10 maps in a plan where you had maps in a plan but in the exercise you, in fact, find that there is a difference as far 33 as your population is concerned when you proceed to start 12 making plans to move them, where you are going to move them, 13 where you are going to shelter them. Thirdly, radiological exposure control -- the kinds 15 of instance I have already talked about as far as planning is 16 Concerned come out in evaluatiods. Here again often times 37 de are talking about the availability of equipment, the distribution of that equipment, how many dosimeters are avail-18 g -3 able, how they are distributed, how many emergency workars have j 19 g them, how they are read. 20 COMMISSIONER GILINSKY: What is the relationship 3 21 .g of these deficiencies to the previous ones? Does this mean 22 that between the time the plans were developed and the exercise 23 took place, enough of the other deficiencies have been corrected so only these remain? Is that the idea? 24 i MR. THOMAS: No. Basically you have 212 planning \\ 25 elements in plan review. You have 74 elements in exercise m.

l 41

• ~

review that relate b'ack to those planning elements. So this (' 2 is not saying that in the plans we found these deficiencies 3 and.in the exercises then that followed, we found these l deficiencies. It just means that if you look at the two 4 i events separately, these generically are the kind of things j i that come'up more than any others as far as problems. l 6 i If you look at a single event or-a single site, 7 you will. find that if in the plan any number of deficiencies l 8 were noted that more than likely a majority of them were 9 corrected by the time of the exercise. One is not mutually l. to exclusive of the other as basically you were asking. COMMISSIONER GILINSKY: Let's take assignment of i responsibility, lack af written agreements. Now it doesn't seem to show up as being a problem when you get to the i /' exercise. Does that mean that these things have been taken care of by the time the exercise has taken place? 4 15 MR. THOMAS: Yes. It means that that comes out in 16 plan review as a fairly general problem, but does not come out - as a general problem in exercise. j7 4 l COMMISSIONER GILINSKY: What you seem to be saying is 18 g t.he review process takes care of that deficiency. l j 19 I -g MR. THOMAS: In plan review, I agree with you. j 20 COMMISSIONER GILINSKY: So the process seems to be i d -l 21 taking. care.of it. It sounds like these are the ones that we l 22-aught to be concentrating on. [ MR. THOMAS: In the exercises', yes, I understand what-23 you are saying and I agree with you. -CHAIRMAN PALLADINO: That doesn't mean the. plan l- - 25 review should not goz o n.- +-.n n ~. v n e --a,., ,,.e

42 ,1 COMMISSIONER GILINSKY-The plan review seems to be 2 T handling these other aspects, these other problems, lack of radiological emergency response training or whatever. 4 MR. THOMAS: Bear'in mind also that point that we 5 made earlier and that is that the exercises that we went back and looked at, we may havc been at a variety of stages 6 as far as plan review is concerned when that exercise was 7 h el d. You may actually have ar. exercise at a plant where 8 there had only been a draf t, a rough draf t, of a plan reviewed 9 before the exercise was held. So you get a number of IO-deficiencies that are noted in the exercise that would have 11 been corrected in a final plan review. So think about the process we went over the lost 12 couple of years. We had both rxercises cranking up and 13 required and at the same time va had planning going on. COMMISSIONER GILINSKi: In any case noti.ication of 15 protective response which is a pretty important area seem not to be working out as well as they should. 17 j MR. THOMAS: I would say that what it identifies is 18 that that is a particularly difficult issue for the state J 19 and locals to deal with. COMMISSIONER GILINSKY: I suppose you are going to g 20 f tell us what you are doing about all this? 21 .. [ - MR.-THOMAS: Yes. 22 (SLIDE.) 4 23 - MR. THOMAS: The last two then, recovery and reentry. 24 planning and' postaccident operations is an issue and an area (. 25 that we have noted in exercises that is of concern and often one that we'have to work with-the state on. Finally, exercises

43 and drills and that relates to the scenario often times and 2 ( the ability to actually test capability as a part of that 3 scenario. Often times, we have to go back and in the second 4 exercise, we have identified specific weaknesses that we felt weren't tested adequately the first time around that we 5 wanted to be sure were tested the second time around. 6~ (SLIDE.) 7 MR. THOMAS: To talk a little bit then about the 8 point you just made, what are we doing and in the analysis' 9 of these is trying to help overcome them, let's talk about to what role we play. We have already talked about the role we play in 11 monitoring and critiquing plans and exercises. The other. role we plan is trying to assist state and locals in dealing with the problems. 14 Now we can't assist them by giving them money. We 15 don't have money to give them to develop the plans or to. buy 16 the equipment or to train the people. We assist them techni-3 17 cally and we also try.to assit them through our other programs that FEMA operates for general emergency planning. 18 1 FEMA has the responsibility under the Civil Defense j 19 y Act to insure that there is a capability at a state. and local 2 20 a level for emergency response that will be available from a h peace time emergencies up to an attack situation. 21 -E 22 So under the Civil Defense Program, we do have ( [ 23 responses available both funding as well as equipment that ( we find is used quite readily in this kind of off site planning 24 ({ and in this capability. For instance, in dosimetry, I will n o t'e ' t h a t. t -~

44 COMMISSIONER GILINSKY: Could you just tell us what ~( the amounts of money involved in those four bullets are in 2 3 your supplemental budget request and the various contracts? MR. THOMAS: The supplemental budget request was 4 disapproved. COMMISSIONER GILINSKY: How much did you ask for? 6 ) MR. THOMAS: A couple of million dollars. It was primarily for additional personnel and some additional contract support. It was disapproved about a month ago. It was for ) 8 9 fiscal year 1982. It is incorporated, the additional funds to are incorporated, in our budget request for fiscal year '83 and it has been approved by both the Senate and the House g Appropriations Committees, so we are encouraged and anticipate I 12 that we will receive the funding for the additional personnel i 13 in fiscal year '83. l# COMMISSIONER GILINSKY: How large are those three 15 contracts?. to MR. THOMAS: The Argonne contract is about a million f 4 I i to a million and a half dollars. It depends on the level of ' j! 37 effort' that is required from Argonne. The way we have j 18 t _C structured that is we have structured Argonne as'a contractor '[_ 19 i g to provide technical support to our reg'ional-offices in plan } 20 i review and exercise critique. We call upon them based on the d 21 a manpower requirements; that we have ' going into a particular i l 22 exercise up to a certain amount of funds that we.can.go into. j 23 I am anticipating-in the coming. year about a million and a half dollars for that Argonne contract. j.. The Idaho Nuclear Enginnering Lab, Vern,.you have the i L -{- 25 specifics on that. i i L

45 1 MR. ADLER: It is about 200. I have the numbers ,~ 2 if you will give me just a' minute. 3 COMMISSIONER GILINSKY: Just roughly. MR. TliOMAS: About $200.000. 4 MR. ADLER: Yes, $200,000 to $250,000. 5 i COMMISSIONER GILINSKY: And the other one? MR. THOMAS: I think that is about $150,000. 7 COMMISSIONER GILINSKY: That is close enough. 8 MR. THOMAS: That one is the one related specifically 9 to the guidance on alert and notification systems. So what to we did during the past year was to try to develop -- one thing we did -- was try to develop additional resources out of our 11 shop to provide to state and locals and to insure that we had l 12 the capability for plan review, we had the capability for exercise critique, that we had proper guidance available to r 14 the state and locals to actually carry out the requirements l 15 that we were placing on them. i 16 Specifically under the generic deficiencies both as { far as plan and exercise are concerned, we had actions underway 37 E where we are trying to addressing that', for instance, the i O dosimetry deficiencies. r j 19 Let me make note first that under the Federal a

j 20 Radiological Preparedness Coordinating Committee that we chair g

j" 21 and that other federal agencies participate on, we have a 22 series of subcommittees. For instance, there is a subcommittee on Federal Response. There is also a subcommittee on 23 Instrumentation and through that subcommittee, there has-been 4' working ongoing as far as what instrumentation is available, what additional instrumentation could be'made available to stater-i

46 l as far as accident assessment is concerned and exposure control c 2 is concerned. 4 3 One of the things that FEMA has as a resource is that 4 under our Civil Defense authorities we do have a test facility at the U. S. Mavy Yard here in Washington where we develop ~ dosimeters both for development and distribution to state and. 6 locals related.to requirements for assessing fall out in an 7 attack situation, also a relationship with the U. S. Navy 8 and their reactor programs are providing equipment for assess-9 ment of radiation levels. in In that regard we have develop.ad low cost self-reading dosimetry. The other dosimeters that we have we do distribute to state and local Civil Defense agencies and we do 12 distribute funds for maintaining the< equipment to state and r local Civil Defense agencies and that is the equipment that l' in a large number of cases is the primary source of equipment 15 to be used.in-these situations. So we have tried to both develop new equipment and 16 if our Civil Defense funding is approved by Congres's, produce 37 additional equipme'nt that would be available to state and locals 18 g4 that could be used in this regard, j 19 g We talked about and we have sent out guidance as far 20 as what substitute devices could be used where there is a d 21 shortage of equipment. We have recommended modified;distributio a 22 pl a n s. We have talked about who needed the actual dosinieter 23 and worked with..the states on what is the best. distribution for actually. distributing those dosimeters.

(-

So we have tied in out expertise over on the Civil m 25 Jefense side into this program and we_have been'very actively.

47 involved as far as 'the equipment is concerned and the 2 {} distribution of that equipment. '3 (SLIDE.) 4 MR. THOMAS: Again as we have noted before as far as the radiological monitoring problems are concerned particu-5 larly through the radiological preparedness coordinating 6 committee'and their subcommittee, there has been active work 7 under way to look at the capability from an equipment point 8 of view as well as procedures for monitoring the radiological 9 pro bl ems. 10 There has been quite a bit of work during the last year again using our contractor, for instance, Oak Ridge 11 National Laboratory, is a contractor to us under our Civil Defense authorities and working with them, Idaho Labs to try 13 / and develop new sampling equipment for assessing radiological 14 material. i 15 . COMMISSIONER AHEARNE: Are these automatic samplers 16 that would be put in pl. ace and kept there or are they samplers { 17 that you could take out when an accident is in progress? MR. ADLER: They are portable and they would be 18- ,s taken as part of field monitoring efforts and brought back. j 19 y MR. THOMAS: For instance, one of the pieces of s 20 } equipment that they have been working on is a modification f of a piece of equipment that is out for civil defense purposes 21 ,-g 22 to be used in a radiological incident at one of these-plants as 23 opposed-to a separate piece of equipment or modification to a c piece 'of equipment that is already available? 24 A. 25 COMMISSIONER _AHEARNE: _ As I recall, there used to be a system and I don't remember what it was that was a nationwide, u

48 in-place system for alerting for a nuclear attack. Are there 2 (- similar type systems -that you are developing or putting in 3 place that would be picking up radiation levels using in-place o 4 systems? MR. THOMAS: No there is not as far as we are 3 2A concerned. What we look to again is the state and local 6 capability'to actually monitor and determine problem areas 7 as opposed to we, FEMA, taking on an operational role to try 8 to do that. We are not doing that.. 9 The area we have already talked about as far as to potassium iodide, there is, for instance, a subcommittee again that has looked at that whole area and there has been 11 t very active involvement by HHS and particularly FDA in that area. 13 Evacuation planning -- we do have a contract for 14 providing basically evacuation modeling and an evacuation 15 simulation facility that we could provide to state and locals 16 to actually take data that is required particularly in the 3 5 17 more highly populated areas and actually develop various 2 simulat' ions for evacuation, various options that they could jg 3 C look at for evacuation. d 19 i CHAIRMAN PALLADINO: Do they have to pay for that 5 20 3 or do you do that? A h 21 MR. THOMAS: We would provide that as dechnical 2 22 support. We are doing it jointly. We have evacuation require-23 ments in a number of our programs both. technilogical hazards and 24 attack related and this is a program. that we are looking to ( to provide a-capability, a technical capability, to state and lochls for all of. those, whether it is to develop evacuation i

49 l ' plans 'for a hurricane which is one that we have a number of 2 }"- activities under way or this or an attack related situation. 3 COMMISSIONER AHEARNE: When will that be completed 4 or when is it estimated to be completed? MR. KRIMM: About 1985. 5 MR. THOMAS: 1985. He had the contract currently 6 under way. We did work on it last year to develop the full 7 scope and we let the contract this year. What we have done 8 short-of that and that is core of an automated capability,' 9 what we have done short of that is that people in our regional 10-offices whether it is people in our headquarters office who i 1 33 are very involved in evacuation planning provi'de technical assistance to the state in their evacuation planning. We have and I am sure you saw during the last year 13 quite a debate over a program that we are responsible for, 14 crisis relocation planning, which relates to a nuclear attack. 15 As a part of that program we have individuals and contractors who work with us as far as evacuation _ planning is concerned 16 3 17 and they are made available to state and locals at their request. 1 18 (SLIDE.)- .- j 19 1 s MR. THOMAS: Prompt decision making process -- here 20 2 again,.we have already talked about the alert and notification a 21 t system. We talked a little bit the other day about the prob-B- 'lems in New England that is the notification and action at a 22 local county level as opposed _to action having to be taken 23 and notification at a _ state level, in other words, how they 24 Work together. COMMISSIONER AHEARNE: You said we talked a little bit i

50 ~1 about the problems the other day in New England. What f. 2 discussion was that? 3 MR. THOMAS: An issue came up about -- I think 4 somebody asked may there be other problems that we are not aware of and somebody indicated that in New England we have 5 noted a problem of authority between local units of '6 government and state agencies. That has been resolved, 7 for instance, in the New York situation, but in some other states we have a problem there and we are working with those 9 states on. it and that is, the notification coming to the 10 locals, notification to thes state, who has the authority -- 11 legal authority-- to actually order an evacuation or order acti,on to be taken. So the alert and notification area, the guidance 13 that we are developing, once we go out with that guidance 14 re intend to provide technical support through our. regional 15 offices to develop the state and local plans. 16 Public education and information, we have had 17 training sessions, several, and we anticipate having another 1 18 in a coming year for public information personnel, particularly 19 y information. Our review of public information documents i 20 and guidance documents.that we have provided has been ongoing to state and local personnel. 22 One of the things that we hope to expand on is our 23 training program for individuals from state and locals. We have 24 training programs now for emergency service personnel in this ( area. We have had training programs about one to two a year 25 for' public information personnel and we want to try to expand

51 l' that in the coming years. [~ 2 FEMA has a national emergency training center at 3 Emmetsburg, Maryland which is a residential center where we 9 provide training. We want to try to increase the training 4 available there for state and local personnel. Additionally, we deploy training at a regional 6 level with contract support personnel and we also provide funding to states for their own in-house training program. 8 All of that is through our civil defense authorities. ~ 9 COMMISSIONER AHEARNE: Could I take you back to 30 the previous one for a minute? MR. THOMAS: Yes. COMMISSIONER AHEARNE: In reference to the generic 12 deficiencies that you had noted before and I want to make 13 sure that I understand what it is that was the generic '4 deficiency, I would gather.from your FEMA' action to reduce 15 the impact, that the deficiency in notification is more 16 related to process than equipment, is that correct? f MR. THOMAS: Yes, and it relates to the guidance or 17 lack of guidance that we provided as far as the criteria is 18 y concerned, the development of site specific criteria for j 19 g avaluation. So I think it relates to a large extent to those O things we now have under development. 4; 21 Recovery and reentry, I indicated that we do have-22 a contract working and we hope to develop that this year. We are doing this ~ jointly with state and locals and particularly-23 with the conference of State Radiological Health Officers to 3 ( develop more specific recovery and reentry guidance. 25-Federal agencies particularly EPA, is involved in that, so the specific guidance for recovery and reentry is one

52 .l I that we think needs to be more defined and provided and we 2 have that under way this year. 3 (SLIDE.) MR. THOMAS: Now there are several other things 4 and I have already mentioned some of them. The exercise 5 evaluation simulation facility was the one I talked about 6 as far as evacuation is concerned and that is underway. 7 Uniformity of exercise criteria -- as it now stands 8 we have criteria that are used in ; exercises. One of the things 9 that I have under way is a review of that criteria to try to and insure that there is more consistency between our regional offices as far as that criteria is concerned or to insure that 11 there is consistency. So we have a review under way and we 12 are updating that criteria. We talked about the ASLB process. We have had 14 training sessions for our people who serve as expert witnesses. 15 Those are conducted by our general counsel's office to insure 16 that those individuals understand fully the scope and responsibilities of your ASLB and what role they play so that 37 I they can be fully prepared to support your Boards as far as 18 g s the kind of findings that they are looking to us for. j-19 - (SLIDE.) s -3 20 i 4 MR. THOMAS: Finally I would note and I have already ^ l 21 noted and that'is the national plan for emergency reponse. I 22 The overall federal radiological eme.rgency plan is nearing completion. The -exercise that I mentioned on October 5th, the 23 exercise in the spring are raajor components of completing that i i. (- process. \\ l 25 j Finally I would like to note several areas to just

53 I reiterate some of the' things we have already discussed. First 2 the difference between the "350" process and what we call the 3 "MOU" process or Memorandum of Understanding that we have with you. 4 Under the "MOU" you ask us for interim findings, you ask u~s to participate in ASLB hearings and that often 6 times those are at an early or intermediate state of that "350" process, and it means that there may be a range of k 8 findings that you get from us according to where we are 9 in that-process. - 10 As to whether a full exercise is being held, for instance,-wi.ll have an impact on what kind of findings we can provide you. As to where the state is, there is a 12 determination on how much of a plan has been completed and 13 t' what we have to review. The final point I have down there, I think we all 15 should bear in mind, and that is that as far as the state 16 and local capabilities are concerned, there is a different i relationship between the work we do with state and locals 37 E and review of their plans and the work, for instance, that 18 .I youido wit'h the utility in review of their capability. .j 19 p You are'a regulatory body. You have the authority i 20 to license or not to license or to delicense. That is not the 21 relationship we have with state and locals. We are there 1' . 22 supporting them. We also are critiquing them. But the process L23 is a. process that is driven by the state and locals and by their ability to develop, by their ability to procure : resources 24 (' to actually do these plans. 25. iI think we 'should continually bear that in mind as we .m' ___l____.__.___.m

54 1 look at the findings you get from us and the timeliness of them, 2 .j-Finally I_noted exercise frequency. You noted the 3. number ~of _ exercises -that were he7 d. I would like to say

4 at the outset,-that I am personally a strong believer in exercises.

I think they are a useful p' art of our ability to 5 assess the capability that a state or a local unit of govern-6 ment has to actually respond, but I am not a believer in 7 exercising for exercise sake. Again, I feel like within our 8 current requirements, we should lo,ok at the possibility of l- ~ 9 some modifications to give us the ability to actually home in to on. partial exercises as Commissioner Asselstine mentioned and possibly defer other exercises in some cases to less or 11 more frequently than once a year. I do feel that flexibility. would be important to us. 13 COMMISSIONER AHEARNE: Lee, when you say you are not 14 in favor of exercise-for exercise sake, I am puzzled by that 15 phrase because the purpose of an exercise is for the exercise. 16 MR. THOMAS: My point there is_that because we have-a requirement that there be an exercise once every'~ year,.I-37 n n n n s once I 18 every year. Put in context the exercises-we do with the 2' -d~ state to the interaction that we have with states on a continu- '8 i,ng basis. I pointed out the civil defense responsibilities J f b we have. During Lthe last year, I have. participated in directing iederal operations in over 30 major disasters and emergencies 23 around this country. As a part of that which doesn't relate at all to 24 (( this, I am interacting with those' states on an ongoing basis with their ability to-deal with emergencies; their leadership,

55 their capability, often times with the same local units of z'p-government that may be involved with a particular facility 2 3 under-your program. I g'uess all I am saying is that if we 4 put in context the total emergency management capability of that state to deal with all emergencies and our agency's 5 interaction with that state and localities to deal with all 6 emergencies, I think there can be flexibility or should be 7 flexibility to make a judgment on how often that exercise 8 should be held related specifically to this and what part ' 9 of the criteria we should exercise whether it is full with to all parties playing, with it is full with all components 11 playing or whether we home in on a specific part or a specific jurisdiction. That is the only point I make really. 13 COMMISSIONER ASSELSTINE: Lee, with respect to the 14 full scale exercises, would you support a more flexible s 15 approach,.for example, that said if a state had a "350" 16 approval and it had anfull scale exercise that did not dis-3 17 close si~gnificant defi.ciencies, they would be given a longer period of time before which they would have to conduct another 18 full scale exercise. j-19 J But conversely, if you had a state that did not 20 - have an approval and where the exercise disclosed serious j deficiencies, you would want to push them and have another 21 I 22 exercise substantially sooner than a year. 23 MR. THOMAS: I think something like that is the - 24 approach I am talking about. ( COMMISSIONER ASSELSTINE: To provide an incentive for' states to do it right the first time and a disincentive

4' 56 1

+ for states who simply don't do the job right or local jf'. governments. 2 3 MR. THOMAS: _Yes. -I think that would be a good 4. approach. p That concludes basically our review of where we 5 are and where we are going with off site preparedness and 6 some of the issues that I think have come up over the last 7 year. 8 -CHAIRMAN PALLADINO: Thank you, Lee. I have a 8~ coupleoof, general questions. I presume these various 10 deficiencies that you relate to particular sites in different ways,.are we working closely enough so that our staff is n alerted to when they are looking bad at a particular' site? HR. THOMAS: Both formal and informal processes 13 obviously for doing that are in place. The ongoing process 14 of our_ interaction with the state, I think, is one that we 15 have to continually strive to improve and that is that short-16 of the formal process I talked 'about, plan review-or exercise, 17 that on an ongoing basis as we and other parts of our program. identify problem areas that we bring that forward and I 18 try to correct that. '19 ~g We do that. I feel that it is an area we continually 20 ~ h ve to push to insure that we are aware of and cognizant of, 3 0 21 ' j that all of our staff is. t 22 CHAIRMAN PALLADINO: What I was trying to get at 23 - isfgetting some of the informal information early enough so that maybe problems can be coped.with before it is necessary 24 (, to initiate the 120 day-clock or someti:ing like that. MR. THOMAS: -I do feel like we have that kind of l

57 '1 I .i n formal interaction with the states and that our regional people, for instance, have a. good feel for where a s' tate is 2 3 in' dealing with problems ~. 4 Quite frankly, some of the problems are extremely di f fi cul t. Some of them relate to a state's ability as well as the timeliness of its response and in some cases I think 6 when you issue, for instance, a 120 day letter they get a different sense of the timeliness than when we try to 8 encourage them. ~ 9 CHAIRMAN PALLADINO: Is there close enough coopera-to tion between our staff and your staff so that we are aware of where you stand on this? MR. THOMAS: I think there is and I would like to 12 commend you and the other Commissioners particularly over the 13 last year I know that you and your staff has really worked '4 well with ours and I think we have a good interaction, a 15 good working relationship. 16 CHAIRMAN PALLADINO: Is there any action that you 37 think that we as a Commission should be taking as a result of } our discussion this morning? It has been very educational for me. -g 19 y MR. THOMAS: I don't think so. I think that some [ 0 of the things we talked about that we want to. follow up on L 5. 21 I would say the relationship of our findings and your ASLB x-22 hearings:is an issue that has come-up a number of times and 23 I think'we are all aware of -- CHAIRMAN PALLADINO: The frequency of exercises, 24 q[E MR. THOMAS: The frequency of exercise'we have talked 25 about. I think nothing other than the things'we have already

58 talked through. 2 (~ CHAIRMAN PALLADINO: I might make a comment with i 3 regard to frequency of exercise and I am sort of sticking my 4 neck out, but I think the feeling of the majority of the Commission is that we are just getting started on this. We 5 agree that we don't want to over burden the system, but we 's ought to gain a little more experience before we start to 7 extend the time between exercises when things look to be going 8 ,3,,g, 9 I expect there will come a time and I am not sure 10 it is not in the far too distant future where I think we will r be more in tune with your thinking than we are at the moment. 11 MR. THOMAS: I understand that. 12 COMMISSIONER AHEARNE: I would think chat you have 13 i a1very good chance certainly starting July of next year. 14 I (Laughter.) 15 MR. THOMAS: It's sooner than I thought, Commissioner 16 Ahearne. l h-17 COMMISSIONER ASSELSTINE: I must say, Lee, I think 2 I am a little more in tune perhaps with your notation of 18 flexibility than perhaps some of my colleagues are particularly 19 g-if it involved giving the grease to the squeeky wheel and 20 8 rgally pushing those states and exercising them with much 21 greater frequency where you have problems. f 22 CHAIRMAN PALLADINO: Having listened to those two l 23 comments, I think it might be sooner than I thought. 24 Other comments or questions? !~( COMMISSIONER AHEARNE:. I have two. First,. Lee, one of'the issues that I know the Commission had addressed in-

59 1 putting together.our side,of this, our emergency plan, was r-2 la a lot of questions coming from both witnin and outside the 3 NRC, was this really needed. We still get'that kind of a question and we still get, I would say, at least a flavor in 5 some areas that we have discussion, is this really needed. 6 I wonder if you can give me a sense when you people who deal so much more closely with the state and local 7 governments and see all the problems they hav' and we have mentioned the resources and demands, do you get a sense from 9 them that they believe that this type of planning is needed? 10 MR. THOMAS: Yes. I don't get a sense that they 11 don't feel it is needed. I get a sense that they do feel 12 it is needed, that it has been while they complain about 13 parts of the process and the frequency of exercise, for instance and those kinds of things, but I don't get a sense at all. 34 from them that they don't feel it is needed. 15 I think a couple of years ago when I was at a state 16 g level and. was participating at a state level in doing this, I what we wanted I think was better understanding of what you 18 felt was needed so we, in turn, had clear guidance. I think j 19 that has been done and that has,been a healthy process, but you will get debate on it but I think generally yes, they feel 20 d that it is needed. 21 .s 3 COMMISSIONER AHEARNE: That is very good. I am very 22 happy to hear that since I pushed very hard to get the rule -23 in and it is good that we get that sense. 24 My other comment was and I guess speaking more for (- 25 the other four who were with me when we did put our side of the rule in and the push that we put in to get an emergency

60 1 planning. rule in and then having participated heavily with ,{ FEMA in the early stages and both agencies struggled. 2 3 I am very pleased to see how much development has come and I realize there are a lot of weaknesses that you have 4 identified. But I know with what little we started and how 5 far we have come, you have come, it is very satisfying. 6 MR. THOMAS: That is an important point, I think, that people who have been in this program a lot longer than 8 I, I think, see that much more clearly. I know where we were, 9 for instance, at a state level in the state I came from when to we began working in this area with your rule and I know what tremendous progress was made, but just in the year and a half that I have been with FEMA, I have seen significant progress 12 in nearly all states and at least we know specifically where 13 there is progress and where there is nct and where the problems 14 area in trying to work to correct those probl ems. 15 I think there has been a lot of progress made. 16 COMMISSIONER AHEARNE: And I think a lot of the credt has to go to you and your stan. h 17 MR. THOMAS: Thank you, sir. 18 g c. CHAIRMAN PALLADINO: Jim, did you have a comment? j 19 a COMMISSIONER ASSELSTINE: Just a couple more things. 20 First, you mentioned the tension between the interim finding f 21 requirements that we impose on you and the "350" process. 22 To what extent at this-point and I know that has been a 23 continuing concern all along, but to what extent right now do the interim finding requirements and your participation in the hearings detract and disrupt frum the "350" approval e \\ - 25 process and your ability to move forward with the "350" a pproval s ?

61 MR. THOMAS: It is a big-manpower drain to, for 2 (- instance, participate in a hearing requires pulling the people who-normally would be wo' king with the state and putting them 3 r 4 on the hearing stand, preparations for the hearing, gathering f interim information. In other words, if a state is moving 5 along wit'h this time frame and there is a hearing coming up 6 or if you, for instance, request a finding, then that stops 7 that_ process, and you, in fact, interject and say we need 8 additional information. So it is a manpower issue. You c'an't 9 plan utilization of your manpower and it means that some of 10 your "350" process is going to slip. 11 It means that you won't get as many plans reviewed or you won't get certain things done because you have to pull people off and put them on something else. Particularly where 13 I it has that effect is in those regions that have a large 14 number of utilities. Our Region V, for instance, which is 15 Chicago or. Region IV, which '- Atlanta, those are the ones 16 where we have a relatively all staff and they have a lot of 3 17 work to be done and so. that diversion to something like that has a significant impact on how much work they can get 1 18 'I* accomplished. j 19 a COMMISSIONER ASSELSTINE: Is there anything more 20 3 that we can do or should be doing to minimize as much as we at 21 t can those disruptions -particularly where all of a sudden you 22 have a requirement that comes on you for an interim finding 23 that you didn't have more lead time for? 5 l MR. THOMAS:- It is really difficult I guess for me 24 { to respond to that because from your staff's point of view I 25 thihk they have to respond to when they feel there is a need l l

62 1 for that kind of information. I recognize that and the ASLB's r 2 I have their-schedules, but some of the things that we have done 3 during the last year jointly with you and some of the rule 4 changes you made, the relationship with low power license and 5 the relationship as to when our exercise has to be completed, 6 were actions that you took that we requested that have had an impact. 7 COMMISSIONER ASSELSTINE: My sense is that the 8 coordination has improved substant'ially over about the past 9 year. MR. THOMAS: My sense is that it has as well. 11 COMMISSIONER ASSELSTINE: I would just add that I 12 agree with John's comment, that I think we have come a long 13 way and I think in large measure it is due to your efforts and J' the efforts of your staff. I remember that you and I chatted g before you came on board and the situation now in terms of your 15 c'apability, in terms of how the process is moving forward is 16 i g far different than it was in those days. 17 j As I recall, at that point FEMA did not have a 18 single person who was assigned and dedicated to this program. j-19 It was one of those borrowing exercises and I think we have a come a long way. E f I would like you to let us know if there is anything l t5at we can do to help move forward the "350" approval 22 process. I suspect although we have made a lot of progress, 23 that there are a number of people including some of the people 24 in Congress that are very concerned and interested in this ( 25 issue and are going to wonder why after the number of-years we have had now, we have 12 out of the 53 sites and only 12.

63 1' MR. THOMAS: 'Right. I think one of the things you 2 .( can do is to help us with Congress in trying to get those 3 funds. You have a lot of contacts up there and I hope you ~ 4. use them. COMMISSIONER ASSELSTINE: Fair enough. 5 CHAIRMAN PALLADINO: Bill, did you or a member of 6 your staff have any comment? 7 MR. DIRCKS: No, I don't think we do. We carry on continuous dialogue with FEMA, too much, maybe. 8 (Laughter.) 10 CHAIRMAN PALLADINO: Lee, thank you very much. We i 11 appreciate you coming over and I join my colleagues in commending your good progress that has been made and I thank Mr. Krimm and Mr. Adler for joining us. Unless there is i 13 1 something more, we will stand adourned. 14 (Whereupon, at 11:40 o' clock a.m., the above-15 entitled meeting was adjourned, to reconvene at the Call 16 of the Chair.) 17 t 18 i 19 a i 20 21 l x 22 23 24 25 l

1 NUCLEAR REGULATORY COMMISSION This is to certify that the attached proceedings before the NUCLEAR REGULATORY COMMISSION in the matter of: FEMA Briefing on Offsite Appraisals Program ~ Date of Proceeding: r,. U n y ; Rontomhav-1A. 1QR9 Docket Number: Place of Proceeding 1717 "H" Street, N.W. 4 Washington, D. C. were held as herein appears, and that this is the original transcript thereof fo'r the file of the Commission. Marilynn M. Nations Official Reporter (typed) A Offi~ciaT(/teporter (Signature) O I e

~ 1 i GENERIC DEFICIENCIES IN l OFF SITE EMERGENCY PREPAREDNESS AT COMMERCIAL NUCLEAR POWER, PLANTS .h September 1982 ---._-.._.__-.._-.._____]

1 j l FEMA'S ROLE IN RADIOLOGICAL EMERGENCY PREPAREDNESS (REP) THE OBJECTIVE OF FEMA'S REP PROGRAM IS TO ENHANCE STATE AND LOCAL CAPABILITIES TO PLAN FOR AND RESPOND TO RADIOLOGICAL EMERGENCIES IN THE FOLLOWING AREAS:

• COMMERCIAL NUCLEAR POWER PLANT FACILITIES
• NUCLEAR FUEL CYCLE AND MATERIAL LICENSE HOLDERS

~

• OTHER NUCLEAR FACILITIES
• INCLUDES DOD AND DOE WEAPONS PRODUCTION / STORAGE / OPERATIONAL AND NUCLEAR FUEL CYCLE FACILITIES
• TRANSPORTATION INCIDENTS k

September 1982 i

FEMA'S PROCESS FOR EVALUATION OF OFF SITE EMERGENCY PREPAREDNESS

• REQUIRES INTERACTION WITH STATE AND LOCAL GOVERNMENTS PROVIDES GUIDANCE DOCUMENTS ASSISTS IN PLAN DEVELOPMENT REVIEWS DRAFT PLANS P

COORDINATES MULTI-STATE PLANS & PREPAREDNESS EVALUATES " EXERCISES". PARTICIPATES IN PUBLIC MEETINGS a tan e ,c ^ September 1982 O m.,.

I- ~ FEMA'S PROCESS FOR EVALUATION OF OFF SITE EMERGENCY PREPAREDNESS (CONTINUED) o FEMA'S FORMAL REVIEW PROCESS (44 CFR 350)

• FEMA REGIONAL OFFICE OBTAINS OFFICIAL SITE SPECIFIC PLAN FROM GOVERNOR REQUESTING "350" APPROVAL i
• PARTICIPATE IN "PUBLIC MEETING"
• FEMA /RAC REVIEW PLAN
• STATE CORRECTS IDENTIFIED s

DEFICIENCIES OR PROVIDES SCHEDULE OF CORRECTIVE ACTIONS

• FEMA REGION SUBMITS PLAN.TO HEADQUARTERS
• INCLUDES RESULTS OF FULL SCALE EXERCISE
• FEMA HEADQUARTERS /FRPCC REVIEW PLAN
• FEMA APPROVES Pi_AN
• LETTER TO GOVERNOR
• LETTER TO NRC September 1982

FEMA'S PROCESS FOR EVALUATION OF OFF SITE EMERGENCY PREPAREDNESS (CONTINUED)

• ADDITIONAL SUPPORT FOR NRC PROCESS
• INTERIM FINDINGS / STATUS REPORTS i
• SUPPLEMENTAL INTERIM FINDINGS i
• ASLB SUPPORT
• PARTICIPATE IN HEARINGS
• PREPARE / REVIEW OFF SITE PREPAREDNESS (SSUES j

RELATIVE TO HEARINGS l l 4 l September 1982 j l l

1 1 j \\ i l 1 ( l FEMA'S EVALUATION OF OFF SITE EMERGENCY . PREPAREDNESS IS A CONTINUING PROCESS THAT DOES NOT END WITH A FORMAL"350" PLAN APPROVAL e e l l l A se.,mt.im2 \\ l l l 1 1 m

DIMENSION OF FEMA'S EFFORT

• PLAN REVIEW (NUREG 0654/ FEMA REP-1) q e'16 MAJOR PLANNING STANDARDS (NOTE: ONE ON SITE PLANNING STANDARD NOT EVALUATED BY FEMA) -ff=4 f%kdR 0" &Y~
• 212. TOTAL PLANNING ELEMENTS ARE REVIEWED
• 169 APPLICABLE TO STATE PLANS
• 96 APPLICABLE TO LOCAL PLANS i.
• PUBLIC MEETING REQUIRED FOR EACH SITE - SPECIFIC PLAN IN THE "350" PROCESS

@k)' l 'I September 1982

o e DIMENSION OF FEMA'S EFFORT (CONT!NUED)

• EXERCISE EVALUATION.

~

• PORTIONS OF ALL 16 MAJOR PLANNING STANDARDS ARE RELATED TO EXERCISE EVALUATION j

(NRC EVALUATES ON SITE PLANNING DURING JOINT FULL SCALE EXERCISE)

• 74 PLANNING ELEMENTS CAN BE EVAL'UATED AT.

EVERY EXERCISE (DEPENDS ON EXERCISE SCENAR'lO.

• FEMA EVALUATES ALL OFF SITE EXERCISES
• ALL PLANTS LICENSED TO OPERATE ARE EXERCISED ANNUALLY AT PRESENT
• ALL EXERCISES INVOLVE A POST EXERCISE CRITIQUE September 19C S

1 l.

VERMONT YAl"KEE EXERCISE D ATE: FEBRUARY 18,1982 q lNVOLVED: 3 STATES (32 STATE AGENCIES) VERMONT MASSACHUSETTS NEWHAMPSHIRE 16 LOCAL GOVERNMENTS FEDERAL EVALUATORS FOR OFF SITE EMERGENCY ^ PREPAREDNESS ACTIVITIES 14 FEMA PERSONNEL 15 FEMA CONTRACTPERSONNEL 8 RAC PERSONNEL _1 FCC REPRESENTATIVE (EBS) 38 TOTAL l i THIS IS AN EXAMPLE OF A NEW ENGLAND EXERCISE l i September 1982 1 , -,. ~

~ Ie FEMA'S ACCOMPLISHMENTS TO DATE

• 53 SITES LICENSED TO OPERATE
• 12 SITES HAVE "350" APPROVAL 11 STATES 35 LOCAL GOVERNMENTS

~

• 41 ADDITIONAL SITES HAVE PLANS UNDER REVIEW 26 STATES 200 LOCAL GOVERNMENTS
• 53 "1ST" ROUND EXERCISES
• 15 "2ND" ROUND EXERCISES 4'"3RD" ROUND EXERCISES 31 SITES WITH pONSTRUCTION PERMITS (NTOL)
• 14 SITES HAVE PLANS UNDER REVIEW 14 STATES 3'4 LOCAL GOVERNMENTS

] s 3 "1ST" ROUi4D EXERCISES O SITES HAVE "350" APPROVAL 3 6 SITES T' HAT ARE PLANNED

• NO FEMA ACTIVITIES PARTICIPATED IN 13 ASLB HEARINGS 8 HEARINGS COMPLETED 5 REMAIN OPEN S'sperntn 1982

~ k e s O m

'C I l FEMA'S FY 1983 PROJECTED WORK LOAD

• 23 FORMAL "350" SITE - SPECIFIC APPROVALS i

=

• 18 STATES
• 91 LOCAL GOVERNMENTS

.i w f ~ W OF 13 DRAFT SITE - SPECIFIC PLANS j - ~~ ~ ..vLUDES FINAL PLANS IN PROCESS) i i

• 15 STATE PLANS l

J

• 53 LOCAL PLANS

? .k- _~ i 7 "' i-: -

• EVALUAiE EXERCISES AT 63 SITES

~

• 9 "1ST" ROUND
• 36 "2ND" ROUND
• 15'"3RD" ROUND'..'

7 '* 4 "4TH" ROUND / t ,1 /* PARTICIPATE IN 9 NEW ASLB HEARINGS j

• 5 REMAIN OPEN FROM PREVIOUS YEARS 1

_.,., % i S^~ j w t _4

1. ' t^"*

,x septab.c w ? ' ~)- f .a

ll

~ m.. i s

• ~

y .y Y 5 = e:

t i ~ e GENERIC DEFICIENCIES NOTED IN PLANS REVIEW 1 s 9O T 16 P N G STANDARDS l A. ASSIGNMENT OFRESPONSIBILITY(ORGANIZATION CONTROL)

• LACK OF WRITTEN AGREEMENTS l

(BETWEEN GOVERNMENT AGENCIES) C. EMERGENCY RESPONSE SUPPORT AND RESOURCES

• LACK OF WRITTEN AGREEMENTS (WITH SUPPORT GROUPS - RED CROSS, ETC.)

E. ' NOTIFICATION METHODS AND PROCEDURES

• PROMP.T NOTIFICATION CAPABILITY (ALERT & NOTIFICATION SYSTEM)

~ G. PUBLIC EDUCATION AND INFORMATION

• LACK OF PUBLIC EDUCATION DOCUMENTS FOR PERMANENT AND TRANSIENT ADULT POPULATION
• LACK OF RUMOR CONTROL Septembw 1982 S

4,. n. -n-....e,., _..,. _,-,

l i t GENERIC DEFICIENCIES NOTED IN PLANS REVIEW (CONTINUED) l t

1. ACCIDENT ASSESSMENT

?

• LACK OF METHODS, EQUIPMENT AND EXPERTISE TO MAKE l

RAPID ASSESSMENT OF ANY RADIOLOGICAL HAZARDS l J. PROTECTIVE RESPONSE ^!

• DECISION PROCESS FOR ADMINISTERING RADIOPROTECTIVE DRUGS (KI) i K. RADIOLOGICAL EXPOSURE CONTROL
• DECISION CHAIN FOR AUTHORIZING EMERGENCY WORKERS l

TO INCUR EXPOSURES IN EXCESS OF EPA GENERAL PUBLIC i PROTECTIVE ACTION GUIDES (EPA PAGS) k L. MEDICAL AND PUBLIC HEALTH SUPPORT

• HOSPITAL HANDLING OF CONTAMINATED INDIVIDUALS t

h i

0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING i

• LACK OF TRAINING FOR DIRECTORS OR COORDINATORS OF l

' RESPONSE ORGANIZATIONS I i a I September 1982 [ i I e 'i

f a 's. s. I GENERIC DEFICIENCIES NOTED IN EXERCISE EVALUATIONS

• GENERIC DEFICIENCIES NOTED IN EXERCISE EVALUATION EXIST IN 5 OF THE 16 PLANNING STANDARDS E. NOTIFICATION METHODS AND PROCEDURES
• PROMPT NOTIFICATION CAPABILITY (ALERT & NOTIFICATION SYSTEM) i i

i J. PROTECTIVE RESPONSE

• PROBLEMS ASSOCIATED WITH EVACUATION (SCHOOL BUS UTILIZATION PROBLEMS, HANDICAPPED i

EVACUATION, TRANSIENT EVACUATION)

• INADEQUATE POPULATION DISTRIBUTION MAPS j

K. RADIOLOGICAL EXPOSURE CONTROL

• LACK OF ADEQUATE SUPPLY OF DOSIMETERS BOTH SELF-READING AND PERMANENT RECORD DEVICES
• LACK OF SPECIFIC ACTION LEVELS FOP. DETERMINING THE j

NEED FOR DECONTAMINATION t l I i' Septembw 1982 l

I L. GENERIC DEFICIENCIES NOTED IN EXERCISE EVALUATIONS (CONTINUED) M. RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS LACK OF ADEQUACY OF PROCEDURES DEMONSTRATED FOR REENTRY AND RELAXATION OF PROTECTIVE MEASURES ALLOWING REENTRY N. EXERCISES AND DRILLS INADEQUATE SCENARIO TO TEST CAPABILITY TO MOBILIZE STATE AND LOCAL PERSONNEL AND RESOURCES i.- September 1982 e l

.t i l l l l FEMA ACTION TO REDUCE IMPACT OF MAJOR GENERIC DEFICIENCIES j i i RESOURCE AUGMENTATION i

• SUPPLEMENTAL BUDGET REQUEST
• CONTRACTED WITH "ARGONNE NATIONAL LABORATORY" l
• CONTRACTED WITH "lDAHO NUCLEAR I

ENGINEERING LABORATORY"

• CONTRACTED WITH " INTERNATIONAL i

ENERGY ASSOCIATES LIMITED" l THE GENERIC DEFICIENCIES (PLAN & EXERCISE) l h HAVE BEEN GROUPED IN MAJOR AREAS OF l CONCERN IN ORDER TO SHOW FEMA ACTION ~.

• DOSIMETRY DEFICIENCIES l
• FEMA HAS DEVELOPED A LOW COST l

SELF READING DOSIMETER DESIGNED FOR LARGE SCALE PRODUCTION

• RECOMMENDED SUBSTITUTE DEVICES
• RECOMMENDED MODIFIED DISTRIBUTION PLANS
• NOT ALL MEMBERS OF WORK GROUP

{ OBTAIN DOSIMETERS ( i l l \\

t FEMA ACTION TO REDUCE IMPACT OF MAJOR GENERIC DEFICIENCIES (CONTINUED) RADIOLOGICAL MONITORING PROBLEMS

• FEMA HAS SPONSORED THE DEVELOPMENT OF A PLUME MONITOR TO QUICKLY ASSESS THE PLUME N

RADIOIODINE PROBLEM

• FEMA CONTRACTOR AND EPA ARE EVALUATING AVAILABLE EQUIPMENT
• PREPARATION OF GUIDANCE DOCUMENT Ki (POIASSIUM IODIDE)
• ESTABLISHMENT OF FRPCC SUBCOMMITTEE TO REVIEW Ki EVACUATION PLANNING
• INITIATE CONTRACT FOR

" EVACUATION MODEL" 4. September 1982 l

4 i e= FEMA ACTION TO REDUCE IMPACT OF MAJOR GENERIC DEFICIENCIES (CONTINUED) PROMPT DECISION MAKING PROCESS FEMA DEVELOPING CRITERIA FOR ALERT & NOTIFICATION EVALUATION

• NRC & FEMA REGIONS REVIEWING PROBLEMS IN NEW ENGLAND 4

PUBLIC EDUCATION AND INFORMATION

• FEMA TRAINING FOR PIO'S
• FEMA HEADQUARTERS REVIEW OF PUBLIC INFORMATION DOCUMENTS
• GUIDANCE DOCUMENTS RECOVERY AND REENTRY
• CONTRACTOR DEVELOPING RECOVERY & REENTRY GUIDANCE AND WORKSHOPS September 1982 e

S

O l 1 l l i i l i f FEMA CONCERNS RELATED TO THE PROCESS i

• "MOU" VERSU,S "350 PROCESS"
• INTERIM FINDING REQUIREMENTS
• ASLB ' SCHEDULING f
• EXERCISE FREQUENCY
• LACK OF FEDERAL AUTHORITIES /

STATE AND LOCAL CAPABILITIES i l ~ l oS September 1982 b e f

^ ^ ^- --^ ^ o +- I* l f i ADDITIONAL FEMA INITIATIVES TO ENHANCE r OFF SITE EMERGENCY PREPAREDNESS i

• DEVELOPMENT OF AN " EXERCISE EVALUATION i

AND SIMULATION FACILITY"(EESF) i

• DEVELOPMENT OF " UNIFORMITY OF EXERCISE CRITERIA" i
• EXPERT WITNESS TRAINING (ASLB)
• DEVELOPMENT OF " NATIONAL PLAN FOR EMERGENCY RESPONSE"(RADIOLOGICAL)

I I September 1982 l

-up . m 1 2/81 -b P TRANSMITTAL TO: f>ocument Control Desk, @b 016 Phillips

5:>;

Pi ADVANCED COPY TO: O The Public Document Room DATE: M cc: OPS File N From: SECY OPS Branch d::= C&R (Natali.e') p -Attached -are'Icopies of a do= mission meeting 8 transcript /s/ and'related meeting documen't/5/. are being forwarded for entry on the Daily AccessionThey % / k b List and placement in the Public Document Room. No / P, other distribution is requested or recuired. Existing DCS identification numbers are listed on the individual .[ documents wherever known.~. ~ p s:> Meeting

Title:

kb M@ f j

• %.c Q W 'O

? - i i v- . h aiG DATE: h l Closed DOS COPIES: I i Copies (1 of each Checked) I m DESCRIPTION: - Advanced May To PDR:

• Original be Duelicate 1.
• Document Dup
• Copy *

(H W m dLAd. I 2.. F g. C

o 3.

2' ~ 4, 5. b h p P

• Verify if in DCS, and M

~ ch'ange to "PDR ~ (PDR is advanced one of each docu:nent, two available." oI cach SECX paper.) r= ll)l l k !k I k I

• }}