ML20027C849
| ML20027C849 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1982 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20027C850 | List: |
| References | |
| NUDOCS 8210270301 | |
| Download: ML20027C849 (6) | |
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OCT 15 198a (1D10RANDUI4 FOR: Richard C. DeJoung, Director Office of Inspection and Enforcenent FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
REVIEW 0F FEt% PLANNING GUIDANCE FOR THE PREPARATION OF THE FEDERAL RADIOLOGICAL EMERGENCY RESPONSE PLANS This is in response to your September 20, 1982 memorandum to Harold Denton requesting a review of the August 1982 draft FEle planning guidance for the preparation of the federal radiological emergency response plans. Attached as Enclosure 1 are our detailed comments.
Our comments relate largely to the overall consistency and presentation of the document. We did not find any major problems with it as it related to NRR support to the incident response function or to the review of licensee emergency response plans. However, it is clear that NRC will need to continue to work with FEl% in defining FEl%'s role relative to events for which NRC is the Cognizant Federal Agency.
Orthalstened by M. R. Denton Harold R. Denton, Director l
Office of Nuclear Reactor Regulation i
Attachment:
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S MEMORANDUM FOR: Richard C. DeYoung Director
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Office of Inspection and Enforement FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
REVIEW OF FEMA PLANNING GUIDANCE FOR THE PREPARATION OF THE FEDERAL RADIOLOGICAL EMERGENCY RESPONSE PLANS This is in response to your Septaber 20, 1982 memorandum to Harold Denton requesting a review of the August 1982 draft FEMA planning guidance for the preparation of the federal radiological emergency response plans. Attached as are our detail'ed comments.
Our comments relate largely o the overall consistency and presentations of the document. We did not find anfmajor problens with it as it relates to NRR support to the incident response functi' n or to the review of licensee emergency response o
plans.
\\Harold R. Denton, Director Office of Nuclear Reactor Regulation
Attachment:
As Stated DISTRIBUTION:
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NRR COMMENTS ON FEMA PLANNING GUIDANCE (FINAL DRAFT - AUGUST,1987.)
Chapter I - Introduction This chapter identifies the purpose, background, planning assumptions, and federal government-wide policies that relate to the development of federal radio-logical energency response plans. The chapter focuses on agency responsibilities and includes little discussion on the private sector response roles.
In the case of nuclear power plant licensees, the functions they provide during an incident are an important factor in the success of the overall federal radiological emergency response. Consideration should be given to expanding Section I.C.1 to include more detail in the description of the role of the private sector.
It would be helpful to include a discussion in this chapter that describes the differences and similarities of agency energency response plans with those of owners and operators.
Exactly how the two interface should be described.
Chapter II Scope This chapter identifies the types of radiological incidents covered by the planning guidance. The scope is consistent with NRC's role in the federal radiological emergency response.
Concept of Operations Chapter III Figure III-l illustrates some geographic terms that relate to a radiological incident.
Consideration should be given to modifying the shape of the zones to be consistent with those of Figure 1 of NUREG-0654. (See Reference 1, p. 4)
In Section III.A.1 it should be mentioned that another role of the owner or operator is to provide information to government officials that is needed for the evaluation of protective measures.
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2-In Section III.A.3 it could be noted that in some instatices owners and operators, state agencies, and federal agencies may all provide parallel confirmatory monitor-ing, evaluation, and recommendations.
4 One of the general responsibilities described in Section III.C.1 of the CFA is t
that it serves as the primary information source for information of a technical i
nature regarding the on-site incident conditions and its potential or real off-site radiological effects.
It would be helpful to add this on the diagram of Figure III-2. This would help clarify the point of contact with the media. Additional discussion about this subject would be appropriate in Section III.C.1.d.
1 Iten III.C.l.c(3) should be listed under Section III.C.1.d.
In Section III.C.1.c an itan should be added that discusses CFA roles in collection and analysis of data.
l There are numerous locations where information is gathered, analyzed, and distributed during an incident.
It would be helpful if the interrelationships of these were l
described. A chart should be presented that depicts the communication channels between, for example, the EOC, EICC, FRMAC, and JIC.
Some considerations of the role of FENA with Canadian and Mexican officials should be presented in Section III.C.3.
It is unclear who's responsibility this would be.
I Section III.C.4 does not discuss the coordination of off-site radiological monitoring, assessment, evaluation and reporting of information obtained by owners and operators.
Particularly during the early phases of an incident this may be the only information available.
. In the Figure III-3 describes the general notification schane for an incident.
case of nuclear power plant licensees, the schene indi.:ates that notification to NRC is from FEMA rather than the plant operators. This is incorrect as the plant operators are required to notify NRC directly. A footnote should be included with the scheme that describes deviations from it.
Planning Bases Chapter IV Section IV.B provides some reference material. Additional references should be added including NRC Report NUREG-0851, " Nomograms, for Evaluation of Doses From Finite Noble Gas Clouds" and to the NRC computer program RADPUR, "A Computer Code for the Evaluation of Doses From Accidental Releases of Radioactive Materials",
NRC Report NUREG-0951.
Under " Planning Basis Concepts", the time from recognition that a serious incident This is in progress... to the beginning of the release" is discussed.
appears to be in conflict with the definition given in Appendix B (p. B-6)
This time should not only be used to determine the appropriate protective measures (as stated on p. IV-2), but also to notify _ the population at risk of the recommended protective action.
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1
. References 1.
U. S. Nuclear Regulatory Commission / Federal Emergency Management Agency,
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparation in Support of Nuclear Power Plants", U.S.N.R.C. Report NUREG-0654, Rev.1, November,1980.
2.
U. S. Nuclear Regulatory Commission, " Nomograms for Evaluation of Doses From Finite Noble Gas Clouds", U.S.N.R.C. Report NUREG-0851, November,1982.
3.
U. S. Nuclear Regulatory Commission, "A Computer Code for the Evaluation of Doses From Accidental Releases of Radioactive Materials", NRC Report NUREG-0951, (Draft December,1982).
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