ML20041A894
| ML20041A894 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20041A895 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8202220647 | |
| Download: ML20041A894 (72) | |
Text
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s NUCIZAR REGUI.ATORI COMMISSION O
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PUBLIC MEETING
. FEMA PRESENTATION ON RULEMAKING
.'ON FREQUENCY ON EXERCISES
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
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4 FEMA PRESENTATION ON RULEMAKING 5
ON FREQUENCY OF EXERCISES 6
7 OPEN MEETING 8
Nuclear Regulatory Commission 9
Room 1130 1717 H Street, N.W.
10 Washington, D.C.
11 Thursday, February 4,
1982 12 The commission met in open meeting at 10:0'S a.m.
13 BEFORE:
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14 NUNZIO PALLADINo Chairman r
VICTOR GILINSKY, Commissioner 1S PETER BRADFORD, Commissioner JOHN AHEARNE, Commissioner 16 THOMAS ROBERTS, Commissioner 17 STAFF MAKING PRESENTATIONS AT MEETING 4 18 WILIAM DIRCKS, Executive Director S. CHILK, Secretary 19 L. BICKWIT, General Counsel B. GRIMES, ICE 20 J. FOUCHARD, OPA 21 ALSO PRESENTS
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22 L. THOMAS, FEMA D. KhIMM, FEMA 23 A. GODWIN, State Depa rtment of Public Health,
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DISCLAIMER ~
This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Comission held on powris,.,v;, 4
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in the Cocmissfon'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 infomational purooses.
As provided by 10 CFR 9.103, it is not part of the forinal or infomal record of decision of the matters discussed.
Expressions of opinion in
.this. transcript do not necessarily reflect final deteminations or
.' beliefs No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any'orize.
statement or argument contained herein, except as the Commission may auth a
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EEOGEEDIE95 2
CHAIRMAN PALLADINO:
The meeting vill come to (3
3 order.
4 Good morning, ladies and gentlemen.
This 5 morning, we are meeting with FEMA to discuss.the 6 frequency of exercises for emergency planning purposes.
7 In November, the staff had submitted a 8 proposed rule change for Commission consideration, which 9 vould change the frequency of emergency preparedness 10 exercises.
At that tim e, there was a lack of majority 11 support for the proposal, at least as presented.
12 After further discussions, Commissioner 13 Ahearne suggested that we meet with representa tives of
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14 FEM A to further clarify the. situation, the other 15 Commissioners agreed.
And I am pleased that we have 16 representatives from FEM A with us this morning.
17 It is my pleasure to introduce them:
Mr.
lee 18 Thomas, Associate Director for State and Local Programs 19 and Support under the Federal Emergency Management 20 Agency.
We have Mr. Aubrey Godwin, Director, Division 21 of Badiological Health'i Alabama Department of Public 22 Health.
He is representing the Organizational Advisory 23 Committee.
24 We also have with us Mr. Dick Krimm, Assistan t 25 Associate Director for State and Local Programs and m
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1 Support, FEHA.
2 We are pleased to have you with us today, and
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3 ve look forward to a fruitful discussion.
4 Unless other Commissioners have additional 5 comments they would like to make at this. time, I am 6 going to. turn the program over to the staff to introduce 7 the subject.
8 MR. GRIMES.
I think that I will just briefly 9 lead off, before I turn it over to lee Thomas, and bring 10 you up to date on the information you have before you.
11 You have, of course, SECY-83-629, which is the proposed 12 amendment, dated November 2, 1981.-
13 I also sent to Commissioner Gilinsky, through 14 Nr. Dircks, a memorandum which in the attachment gives 15 the exercises that have been held to date, and those 16 that will be held in the next two months as background 17 information, and also responding to his inquiry about 18 how the regional administrators felt about the subject.
19 I think it might be appropriate to note 20 briefly that on the question of whether there should be 21 a flat extention to a two-year timeframe, the regional 22 administrators were not-in favor of that.
I have subsequently talk'ed to the staffs that 23
- 24. staff responses for the regional administrators, and 25 they feel strongly that there need to be some form of ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 454-2345
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1 ability to require an exercise if there are major 2 problems identified.
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3 FEMA also feels that this sort of thing is 4 needed, and Lee Thomas. will help us to do that.
I 5 believe that with this sort of modification that Mr.
6 Thomas will speak to, I think the regional
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7 administrators will be in favor of the change.
8 COMMISSIONER GILINSKYs What is the change 9 that you are talking about?
10 MR. GRIMES The change to the proposed rule 11 would be to explicitly indicate that, if there is a 12 particular problem identified in an exercise, that 13 component or another full exercise, if necessary, should
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14 be held more frequently than every other year.
15 The idea has always been there, and the 16 proposed rule is silent on that because the thinking of 17 the headquarters staff was that we had a four-month 18 clock type of thing that we could identify deficiencies 19 in, and always require'd that additional exercises. would 20 h eld.
21 But I think needs to be very explicit, and 22 people need to expect that, if there are problems during 23 an exercise, that at least those components tha t had xJ 24 problems would need to be exercised.
25 COMMISSIONER GILINSKY:
This added wrinkle is ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON. D.C. 20024 (202) 554-2_345 __
5 I'N 1 not in your meno.
2 MR. GRIMES:
The added wrinkle is not in the (m
3 memo, and would have to be staffed with the 4 Commissioners' assir.ta nce.
5 COHNISSIONER GILINSKY On that point, could I 6 just ask you, I don 't want to delar the meeting unduly, T but: when you said the staff was in favor of this, and it 8 turns out. that the regional administrators are not,. what i
9 does it mean?
10 HR. GRIMES:
When I went out to the regional 11 administrators, I simply asked them to respond to your 12 question about the two-year interval, and they initially 13 responded negatively.
14 COHNISSIONER GILINSKY:
But in the earlier 15 paper, you said the staff was in f avor of changing it to 16 a two-year cycle.
17 HR. GRIMES:
That' included the headquarters 18 staff and our discussions with the regional people.
19 Since that time, ther, perhaps, have had more 20 exercises.
21 HR. DIRCKS I think'it was called to their 22 attention.
What I gather, as Brian has explained to me, 23 this paper was distributed, that this paper was l
(s 24 distributed to the regions, and they had no comment.
25 When you asked the specific question, and it was phrased l
J ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554-2345
6 1 tha t way, then they came back with an answer.
But I 2 think the first time around, they just gave it a pass,
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3 and the second. time around, since you asked directly, 4 they came forward with an answer.
5 CHAIRHAN PALLADINO:
Were the regional 6 administrators unanimous on their ansvers?
7 MH. GBINESt I would say that they different 8 degrees of disagreement, but they all expressed concern 9 that perhaps we did not have enough experience yet to 10 flatly go to a no more than two-year frequency.
11 As I point out in my response to Commissioner 12 Gilinsky, and I think we have to rely fairly heavily'on 13 FEM A for a judgment on that, but as it turns out, I
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14 think FEMA is in agreement with. that judgment, and they 15 believe also, as they will discuss, that there has to be 16 sone provision to exercise a little more frequently than 17 every other year for problem areas.
18 CHAIRMAN PALLADINO:
I wonder if I could make 19 sure that we not only talk about one aspect of this 20 subject, but see the integrated picture.
For example, j
21 there is the site and local exercise, with perhaps 22 partial State input.
There are State exercises that l
23 have to be fully implemented with each site, and then l
24 with at least one site, and there is Federal l
25 participation.
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I was wondering, as we go along, can we clear 1
lt up all of these points, so that when we are through, we
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3 have a clear picture of the whole set up.
4 MR. GRIMES:
Lee, would you like me to go 5 through the various degrees of participation, or would 6 you like to?
7 MR. THOMAS:
That is fine,and then I will go 8 behind you.
9 MR. GRIMES I think ti.ere are several 10 different aspects spoken to in the rule.
The first is 11 the licensee exercise, which would involve the 12 activation of the licensee's facility emergency response 13 organization as called for on an annual basis.
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14 CHAIRMAN P ALLADIN0 s That is up to the site 15 boundary?
16 MR. GRIMES:
Up to the site boundary, and it 17 would also check communication links outsid e, for i
18 example.
l 19 The second one is a full participation 20 exercise, which would involve a deployment of both the 21 local authorities and the State authorities in whatever 22 role they have for that particular site.
That is called 23 for on a frequency of at least once every seven years I
l 24 for each site.
However, there is a requirement that the l
25 State participate at least once every two years --
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COMMISSIONER AHEARNE:
Are you talking about 2 your proposal, or as it is now?
3 MR. CRIMES:
No, the proposal.
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There would be a requirement that the State 5 participate at least everr two years in a full-scale 6 exercise.
This would mean, for example, that a state 7 with only one facility would not exercise only once 8 every seven years, but.once every other year.
9 CHAIRMAN PALLADINO4 So this last one, the 10 State would exercise f ully with one of its plants every 11 two years.
12 HR. GRIMES:
Every two years, yes.
13 There is a further requirement that.the local 14 governments also exercise with partial State 15 participation every two years.
This insures that for a 16 state with, for example, seven facilities, although the 17 State is exercising once every year, there is a periodic 18 exercise eith at least the local government and a 19 partial participation of the State government on some 20 f requency more of ten than every seven years.
21 The-various combinations are given in the SECY 22 paper in the form of tables which indicate possible 23 schemes.
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24 COMMISSIONER GILINSKT:
This is 6297 25 HR. GRIMES:
Yes.
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400 V:AGINIA AVE., S.W WASHINGTON. D.C. 20024 (202).554-2345
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It indicates possible schemes for exercising 2 which involve full and partial participation.
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3 CHAIRMAN PALLADINO:
What about Federal 4 participation?
5 HR. GRINES:
Federal participation is not 6 directly required by the rule.
Our rule does not levy a 7 requirement directly on other Federal agencies, bur it 8 does say that facilities must make provision to allov 9 for participation of Federal agencies at least once 10 every seven years at each site.
11 It is desirable to have Federal participation, 12 and Lee will discuss some problems that have occurred in
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13 getting some of the Federal agencies to participate, and 14 the need for some mechanism to better assure that 15 participation.
I will leave that for him.
16 CHAIRMAN PALLADIN04 Would it be appropriate 17 to take a moment to look at one of the tables, the one 18 that shows seven sites?
19 MR. GRIMES :
Sure.
20 CHAIRMAN PALLADINO:
If we look at that table, 21 Site A would have a full-scale exercise, let's say, at 22 year one.
Then these Ps, I presume, is the site, local, 23 and partial State participation.
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24 HR. GRIMES:
Yes.
25 In the blank years there would be a licensee
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554 2346
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2 CHAIRMAN PALLADINO:
Okay.
3 Nov look at the second plant, and look at the
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4 diagonal where all the Ns are there, that would mean 5 that the State that had seven sites would be really 6 involved in a full exercise every year.
7 MR. GRIMES:
That is correct.
8-CHAIRMAN PALLADINO:
Then there are variations 9 on that.
10 MR. GODRIN:
I think we should also point out 11 that the communications part of the annual site exercise 12 leads to checks ' notification to the State, and usually 13 all the way down to the locals.
So that part is being
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14 checked annually.
15 CHAIRMAN PALLADIN0s I was trying to make sure 16 I understood tha t reference point and be able to handle 17 together in my mind how the' plan was developed.
18 COMMISSIONER GILINSKY:
Brian, I wonder if you 19 could clear up something about the roles of NRC and 20 FEM A.
21 Your original paper talks about emergency 22 planning exercises.
It touches on the fact that. in 23 consultation ' vith FEMA, but you have pretty much taken (s
- 24. it on yourself -- you talk about cost / benefit analyses, 25 and so on, and you say something about cost effective.
ALDERSON REPORTING con 4PANY,INC,
_ 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (201).554 2345
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In the latest memo, you just say, in effect, 2 the NRC does not have expertise in outside emergency
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3 preparedness, period.
Was your earlier conclusion 4 arrived at on the basis of FEMA advice that they were 5 vriting the regulations, because there was~ no mention of 6 it?
7 MR. CRIMES:
It was really based on working 8 with FEMA, with the Organizational Advisory-Committec, 9 of which Mr Godwin is chairman now.
10 COMMISSIONER GILINSKY:
When did FEMA advise 11 us that they were changing the regulations?
12 MR. THOMAS:
Let mc speak to the issue.
Let 13 me give you a little background.
14 Along about last Eugust, we began a review of 15 several different issues in our rule, jointly with NRC, 16 that related to both licensing of new plants and 17 exercise of existing plants as a part of our review of t
18 finalization of our rule, 44 CFR 350, which we hope to 19 put in final form this Spring.
That rule has been 23 consistent with NRC, a s it should be.
21 So we began a joint review, then, of a number 22 cf issues in there.
Several, for instance,'this 23 Commission has already taken up -- low power licensing, 24 the scheduling of exercises prior to full power,.when.se 25 are looking at licensing of a new plant as opposed to a t ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554-2345
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1 the hearing stage.
A third would be the frequency of 2 exercises.
All of those changes that are being proposed
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3 by NRC, we will incorporate into our final rule, the 350 4 rule.that will go out this Spring.
5 A s: Brian said, we worked jointly on it.
That 6 is just where we started from.
We started jointly, that 7 f ar back, really working on this issue.
8 COMMISSIONER GILINSKY:
Let's see, you are 9 saying that this change was proposed by NRC, and Brian 4
10 is saying that it was proposed by FEMA.
11 MR. THOMAS:
No.
I guess I am saying it is 12 proposed.
As to where it originated, I have no probien 13 in saying that it originated with us.
The specifics, 14 though, of exactly how we then come to frequency of 15 exercise, I think was a joint process of working 16 together staff to staff.
17 We proposed that we felt frequency of 18 exercise, the issue, needed to be addressed as we l
19 revised the rule.
20 MR. GRIMES:
The NRC, then, provided the first 21 draf t which was then discussed with FEM A, and 22 subsequently with the IOAC, of a possible exercise 23 frequency scheme.
I think this was also focused on by
's 24 the Chairman 's meeting with --
25 CHAIRMAN PALLADINO:
I was going to suggest ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554 2345
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1 that maybe we allow Mr. Thomas to make the presentation 2 in the way he had planned, then we can come back to
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3 questions.
4 MR. THOMASs.
I started it.
5 (General laughter.)
6 MR. THOMAS:
So, I will skip over that first 7 part about what we started last August.
8 I did want to, basically, make a few opening 9 remarks about the issue of exercises.
I think FEM A 's 10 and NBC's participation in review of State and local 11 exercises has been particularly active in the last two 12 years, since we really began the process, with new 13 rules, of reviewing the State and local full
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14 participation exercises, critiquing. those, the whole 350 15 process as we ref ar to it.
1d In that last two-year period, there has been a 17 considerable amount of activity.
If my people are back 18 there, they are going to show you some charts that are l
19 reflective on some of the things that Brian already 20 showed you.
21 As you can, the number of sites in a state 22 ranges from one to seven, Illinois being the one state l
23 now that has seven.
When the rule on exercise was j
24 promulgated, we had one state with five, and now it has 25 gone up to one with seven.
You can that the 39 sta te s i
ALDERSON REPORTING COMPANY. INC.
400 VIRGINTA AVE., S.W., WASHINGTON D.C. 20024 (202).554 2345
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1 are arrayed in this fashion.
2 We have had 55 full-scale complete exercises,
('i 3 that is basically within the last two years, that FEMA 4 and the NBC have been involved in critiquing those 5 studies.
As.you can see, we have exercises scheduled in 6 a number of those states.
7 We will have an exercise completed within the 8 timeframe established by you of April 1 of'this coming 9 at each of the sites throughout the country that have to f acilities.
11 What we have had going, obviously, in the last 12 two years is not only exercises at f acilities that are
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13 operating f acilities, but enarcises at facilities that 14 were preparing to be licensed, or that you were 15 reviewing.
So we have had that combination.
16 It has been a significant process in a number 17 of states, as the next overview will show.
You can see 18 tha t in some sta te s, for instance, Wisconsin and 19 Illinois, in that last two-year period they have had 20 five full-scale exercises because of the number of 21 plants they have.-
l 22 CHAIRMAN PAL 1ADINO:
din the last recr, or the 23 last two years?
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24 HR. THOMAS:
Two years, since we have begun 25 this process.
Obviously, prior to tha t. there were i
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1 numerous exercises, but I am talking about under our 2 existing rule, when we talk about full-scalo, and the (v
3 critique that we give.
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The next slide will show you that the states S-that have not yet been exercised, where we have 6 facilities or where there are facilities that will be 7 considered f or licenses, are in that following order.
8 The ones that have no date, it is because the licensing 9 date or. the construction date is so far ahead, a date 10 has not really been scheduled for any meaningful 11 exercise.
12 Just to take you.through, then, and take a' 13 look at the existing rule and the proposed rule, let me
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14 run through this.
This is why I think the comment that 15 Brian was making, the comments that I am prepared.to 16 make, I think we can discuss, maybe, each element of the 17 rule.
18 COMMISSIONER BRADFORD:
Let me ask you one 19 question about the schedules.
Why in the case of Indian 20 Point, or any other site where this is true, do you. have 2t two 'different exercises scheduled a few months apart, if 22 I have read the schedule correctly, one for each unit.
23 HR. GRINES:
I think I should. speak to that, 24 because it is called for in our rule.
But, each 25 licensee at each site must exercise at a certain ALDERSoN REPORT:NG COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202).554-2346
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1 frequency.
We think that it is 'important that the 2 actual emergency organization of the licensee exercise
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3 witht the off-site authorities.
4 If you have a situation where the same 5 licensee has 'two units the same corporate organization e
6 supports those units, and it is the same site 7 organization that supports those units, it is quite 8 acceptable. to have one exercise for the site.
Where you 9 have two different emergency organizations, we think it 10 is important to treat those as really two separate 11 sites.
12 COMMISSIONER BRADFORD:
So the State an'd local 13 entities have to crank up twice.
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14 MH. GRIMES:
In the near-term,for the first 15 time around, we would. like th a t.
In the long-tera,.ther 16 would he treated like two separate sites, and they l
17 would, indeed, be treated as if the facilities were, 18 say, 10 to 20 miles apart, but still affecting the same 19 counties.
20 For example, Peach Bottom and THI, both affect 21 York County.
Indian Point Units 1 and 2, both affect 22 Westchester County, for example.
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23 HR. THOMAS *-
I think you are probably all
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24 familiar with what is involved, when we talk about a 25 full-scale exercise, but the elements that we required i
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1 in the plan are 16 major elements, and basically are 2 exercised in a full exercise by State and local
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3 governments.
4 Our critique of this exercise and forwarding 5 of findings.to you are based on each,of these elements 6 -- direction and control, communications, whatever, on 7 each of those elements.
8 A full-scale exercise is basically as its name 9 implies, it is full-scale in the field, State and local 10 units of government, with licensee, exercise.
The 11 exercise may range from a day to two-day exercises.
12 When I talked about the fact that the 13 exercises, particularly in the last year, have been
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14 numerous, it is because of the activity with near-term 15 operating license as well as the existing plant exercise 16 requirments.
17 I, myself, for instance, ran two full-scale 18 exercise in a state within a three-month period of 19 time.
The problem we have found on off-site 20 preparedness is, it is almost a point of State and local 21 governments cranking too often for a full-scale exercise 22 because of the existing rule.
Therefore, we support 23 this modification in f requency of exercise with some (s
24 clarifying language, and this is what I would suggest.
25 COHNISSIONER GILINSKY.
What is the rationale
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I) 1 now for that?
2 HT.. TH05AS:
Let me do-this, as I go through
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3 each one, let me present a rationale.
COMMISSIONER GILINSKYs Sure.
5 NH. TH05ATa-I will read you the component.
6 The existin7 rule requires that the licensee 7 exercise annually.
The proposed rule requires that the 8'. licensee exercise annually.
'de are suggesting that 9 minor additional language be put in this, similar to. the 10 language that you have in your proposed low power 1t licensing rule, which clearly identifies the fact that 12 for the licensee to exercise, it requires some off-site 13 support.
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14 If he is going.to exercise his communications 15 link, alert link, obviously State and local, to a 16 certain extent, have ~to support that.
Therefore, in 17 order f or you to fully critique that licensee's 18 exercise, the State and local are going to have to 19 support that.
I think that that is what Mr. Godwin.vas 20 talking about a minute ago, that annual exercise of the 21 licensee vill require some State and local support, so 22 that you can have a full critique of that.
23 That is basically the same kind of language 24-you have in your low power proposal.
25 The second one, which is, in the current rule, a
9.
s ALDERSON REPORTING COMPANY,INC, 400 VIAG!NIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 454-2345
- 19 I) 1 you require full-scale and small-scale exercises are 2 required to include State and local government
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3 participation on an annually basis.
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4 Basically, what we are proposing is that ve go 5 from an annual to a bi-annual full-scale exercise, but 6 we suggest, and we have been working with Brian on thate 7 that we talk in terms of "in the off-year," or af ter 8 that. full-scale exercise.
9-In the critique of the full-scale exercise, 10 where deficiencies are noted, whether it be local, 11 State, or both, or licensee, where deficiencies are 12 noted, that we specifically then will require another 13 exercise prior to the next two-year cycle, and that it
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14 may be anywhere from a full-scale down to a partial 15 component exercise.
16 By that, I mean, if the exercise is a very 17 poor exercise, and in the opinion of FEMA, or in 18 consultation with NRC, we feel another full-scale 19 exercise should be ordered, then we would set a date for 20 another full-scale exercise.
If we feel that a 21 component of. that should be exercised, for instance, 22 direction and control, or the communications link, or i
l 23 the evacuation procedures, then we would require an 24 exercise for those components.
25 Our people in the field feel that this gives
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L ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON. O.C. 20024 (202).554 2346
10 I"i 1 us the opportunity, in the off-year, to work on the 2 deficiencies or the weaknesses that we have noted in the
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3 previous year.
4 Additionally, we feel that we should 5 specifically state that we would be able to require an 6 exercise in the off-year if we felt it was required for 7 any other kind of changing conditions, if we felt.that 8 it was necessary because of a' change in local government 9 authorities that was significant to the point that we 10 felt we should have a full-scale exercise in a 11 particular area, or whatever reason during that 12 off-year.
13 We would look at the off-year as the year f
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14 where we would really work on correcting, dealing with 15 deficiencies that were dealt within the f ull-scale 16 participation exercise.
17 CHAIRMAN PA11ADINO4 Does this mean that the 18 sta tes that have seven. sites, w'here one of the sites 19 would have a corrective type of review as well as a 20 full-review?
21 HR. TH0HAS4 What we are. talking about really 22 affects those states that only have one.
23 CONNISSIONER GILINSKY:
Does any state-
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- 24. actually - hav e seven sites?
25 HR. THOMAS:
Yes, Illinois.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202).554 2345
21 I) 1 COMMISSIONER GILINSKY:
They will have seven 2 reactors, are they all sites?
3 MR. GRIMES:
There vill be seven sites.
They
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4 are Dresden, Quad Cities, Zion, Braidwood, Byron, 5 Clinton and laSalle.
6 COMNISSIONER GILINSKY:
They do not.have seven 7 sites there now.
8 HR. GRIMES:
. hey don't have seven,.they have S three down there right now, so they are in the three 10 category right now.
11 HR. THOMAS.
I guess the area ve are really 12 talking about is when get back to the states that have 13 one site, because when you get in seven, or when you
(_'I 14 into multiple, you. vill take your corrective actions as 15 a part of the upcoming partial, although you may want a 16 partial at a particular site in eddition to the partial l
17 another site.
We are saying that we feel the language 18 should state that FEMA specifically, in working with 19 NRC, can require that off-site additional exercise.
20
, COMMISSIONER GIIINSKY How would you feel 21 about adjusting your proposals so that if you give a i
22 State a sufficiently mark, they don' t have the exercise
- 23. the following year ?
_)
24 I will tell you what concerns me, I think we 25 are too early in this process, and we have too little
,3
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22 I) 1 experience to let the states off.
When they do perform 2 vell, fine, we can go to a lower frequency of testing.
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3 But do you feel that the States have done so well up to 4 now that you can be comfortable with a two-year cycle?
S NHL THOMAS:
I think some of the States.have?
6 COMMISSIONER GILINSKYa Which ones would you 7 say have?
8 HR. THOMAS I think South Car,olina has, to 9-give you a specific example.
10 COMMISSIONER GILINSKYa That is one.
I 11 suppose you could give South Carolina a good mark.
12 HR. THOMASs The reason I tell you that is' 13 because I know that from personal experience.
I can go
(_,
14 back through them 15 COMMISSIONER GILINSKYt Then you have the 16 option to give them a good mark, and they are on a 17 two-year cycle.
18 MR. THOMAS:
Then you put the burden on the 19 other ones 20 COHNISSIONER GILINSKY:
That is right,. where 21 it ought to be, it seems to me, on the other States.
22 It is your agency that has the expertise, and 23 if you say a State has performed splendidly, fine, let's 24 put them on a two-year cycle, or whatever you think is
~
25 appropriate.
But I don't think that it ought to be so
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1 easy for a State.
I don't think the burden ought to be 2 on you to start finding all sorts of little things, be
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3 aguing about whether it is significant, and how much of 4 it has to be repeated and so on.
5 HR THOMAS:
I think it is now, and rightly-6 so.
The burden should be en us, I think, as a part of 7 the critique of that State, to go back to the State with 8 specific findings, just as we come to you with specific 9 findings..
I think we have the burden on us to back to 10 the States and say, "We feel like you need to have a 11 full exercise."
12 COMMISSIONER GILINSKYa If you said tha t 30 13 States had performed tremendously well, or 20 States had 14 performed tremendously well, that is one thing, then we 15 would deal with the exceptions in the way that you 16 suggested.
But, in fact, if it is a small number of
^
17 States that we can say have performed well, then I think 18 it ought to work the other way.
The standard ought to 19 be the one-year standard, and for those perform well, by 20 all means, let's relax the standard.
21 NH. THOMASz I guess we are getting to the 22 same point, it is just where the burden rests as far as l
23 how we get there.
24 COMMISSIONER GILINSKY:
Right, but the result 25 m ay be different, depending on how we set this thing up, ALDERSON REPORTING COMPANY,INC, 400 MRG1NIA AVE., S.W. WASHINGTON, D.C. 20024 (202).554 2345
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24 I'
1 in terms of what actually happens in the way of 2 exercises.
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3 MR. GRIMES:
If I.could make a comment from 4 the NBC standpoint, two comments.
One, I think people 5 respond to expectations a great deal, and I think we are 6 better off writing our rule with the expectation that 7 they.will comply and perform well, than if.we did not.
8 The second is, I have seen a lot of exercise 9 results where specific minor components are identified.
10 as needing rework, and there is no problem, even though 11 it is not an explicit regulatory requirement with
~
12 getting those items exercised.
13 It seems to me that the nature of bureaucracy
(
14 is to sometimes take the easy way out, and I think it is 15 important to force ourselves to come to a specific 16 judgment on the adequacy of exercises.
If I give 17 somebody an option of no action means that things must 18 go on at a high frequency,.I think I would like to f orce 19 them to come to a specific judgment on the issues and 20 identify very specifically the things that are wrong in 21 order-to justify aq additional component or full 22 exercise.
2c.
COMMISSIONER GILINSKY :
The answer is 24 obvj.ously not to have exercises.
25 MR. THOMAS:
I think from our point of view,
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25 d
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1 the position that we are trying to take on it, we feel 2 the exercises are of critical importance to State and 3 local units of government, and the licensee.
We would 4 like to see the exercises 'be as meaningful as possible.
5 We feel like that if ve-have the option of 6 exercising those components of a full-scale exercise 7 that.ve feel need to be corrected or where deficiencies 8 vere. exhibits, that will give us the opportunity, i.
9 working with those State and local governments, to do 10 that, give them off-year to really through problems 11 noted.
12 There is still the full capability to have'a 13 f ull-scale exercise every year, even in a State that 14 only1 has one plant.
15 COMMISSIONER GILIFSKY:
Yes, but you are 16 setting up a two-year standard, and you are working 17 uphill to go from there to one year, or some partial 18 test in one year, and you are going to be handling this 19 thing.
20 How do you feel, do you feel comfortable 21 relaxing the standard at this point,. based on the 22 performance of the States?
23 HR. THOMAS:
With the modifications I noted, I 24 d o..
With the language I am suggesting, that I talked to 25 Brian about, I do.
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202).554 2345
4 26
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1 Our regions, we canvassed our regional 2 directors, and our regional RAC chairmen, our Regional
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3 Advisory Committee chairmen that era within the staff, E
4 and I think they support the chance we are talking 5 about.
6 COMMISSIONER GILINSKY What do you.think will 7 be the. result in terms of requiring additional exercises 8 in what you call. the off-year?
9 HR. THONAS:
I think the basic result will be 10 that every State will have a partial or a component 11 exercised every year, to a certain extent.
It will not 12 be a full-scale exercise every year as we currently 13 have.
In some states, they will only be exercising, for
(
14 instance, the direction and control component, or-the 15 local covernment will be exercising fully, and the State 16 supportina.
17 I think it will give ns the flexibility to 18 focus on those components that need to be focused on, 19 without requiring that full-scale of everybody in the 20 field, which I think actually is having a nr,qative l
21 effect in some cases, in that you are pulling people in 22 the field on an exercise who performed very well the 23 year before, and really don 't need to be exercised.
In
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24 that. second year, you need to be able to focus and 25 concentrate on those elements that you felt were ALDERSoN REPORTING COMPANY,INC, 4M MA AVE, SW, WASHNoN, D.C. 2M24 (202M64 2M6
27 1 deficient.
2 COMMISSIONER AHEARNE:
Lee, how many States (3
3 have had more than one full-scale exercise?
4-NR. TH0HAS:
That.was on one of the slides.
5 We have had as many as five.
6 COMMISSIONER AHEARNE:
Five exercises, is that 7 full-scale exercises?
8 NR. THOMASs Yes,.those are full-scale.
9 NR. GRIMES:
I believe if you look at the 10 table in the response to Commissioner Gilinsky, it is 11 listed by state.
This is a slightly different basis as 12 a f ull-scale exercise since January 1, 1981.
There is 13 Illinoir, for example, with three exercises, and Iowa
(
14: with three.
15 COMMISSIONER AREARNE And Wiscensin with 16 three.
17 HR. THOMAS:
Fiftaen.
18 COMMISSIONER GIIINSKY:
Let me ask you this, 19 on the basis of the exercises, would you have allowed 20 any of these states, or how many of them, not to have 21 any exercise the following year?
22 HR. THOMASs I don't know whether we would 23 have on any of them, in other words, having a completely
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24 off year.
I can't answer that.
My reaction would be 25 that probably in the majority of cases, we would have O
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28 O
1 been exercisinf component.
2 For us, as you know, a component that we are 3 particularly concerned about at this point is the alert 4 notification component.
So we are going back and we are 5 exercising alert notification components in a number of 6 places 7
COMMISSIONER GILINSKYs I must say, I would be 8 auch more comfortable, I think the States would respond 9 auch better, if it was a matter of you giving them a 10 suf ficiently high mark that either an exercise or part 11 of an exercise was no longer required.
12 NR. THOMAS In the last two years, we have 13 had multiple exercises in 15 states.
They.have ranged 14 from two exercises to five exercises in a state.
15 CONHISSIONER AHEARNE:
Those were not full 16 exercises?
17 HR. THOMASa Full exercises in 15 states.
18 HR.. GRIMES:
I think that some of the 19 multiples might have been partial.
20 HR. THOMAS:
Where the State participated in a 21 f ull-scale exereise ?
22 CONMISSIONER AHEARNE:
There seems to be a 23 significant difference between --
(s 24 MR. THOMAS:
Between what Brian has and what i
25 we have?
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1 COMMISSIONER AHEARNE:
Yes.
2 MR. THOMAS 4 It may well be that some of those
()
3 were partials.
4 MR. GRIMESt I think the time period is a 5.little longer, too.
He goes back two years, and we go 6 back. essentially a year.
7 COMMISSIONER GILINSKY:
Let me ask you 8 something else here..
We are now talking about modif ying 9 the proposal, you are suggesting it from one end and I 10 am suggesting it in a little different light, but in any 11 case modifying it so that there will be a provision-for 12 testing at least those parts of the plan that have not 13 worked as well in the full-scale exercise as they should 14 have.
The original proposal was, however, to switch to 15 a flat-two year basis.
16 MR. THOMAS:
There is a component of that I 17 think no has mentioned, and that is the one that we have 10 kind of taken off on in talking with NRC about expanding 19 it a little, and that is the one talking about table-top 20 protective action decision-making drill, which was going 21 to be.re' quired in every state, but it wasn't full 22 participation each year.
23 I guess what we are saying is that we are l
24 recommend that that be expanding to cover the kind of s
25 things we talked about.
ALDERSON REPORTING COMPANY,INC, 400 VIR'11NIA AVE., S.W., WASHINGTON D.C. 20024 (202).554-2346
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CONNISSIONER GILINSKY:
What I am trying to 2 get out of this is, what is it that motivated you, what
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3 was. the basis for your proposal when, in fact, it looks 4 as if, on the basis of these new ground rules we are 5 talking about, you would be exercising at least part of 6 the plan in most of the states?
7 What is it that led' you to think that it would 8 be okay to. go to a two-year-basis?
Is it your
- 9. evaluation of the states, is it our suggestion, or to what?
11 HR. THONAS:
I think we are still saying that 12 it should be a two-year basis.
We are just sugesting
(.__
13 that we expand severel of the provisicus in there to 14 include our ability to require that component review in l
- 15. the off-year.
16 I guess what we are saying is, we want to be 17 sure that the States understand tha t this doesn ' t mean 18 they are going to have an off-year.
It may well mean 19 that they could hav a full-blown exercise in that 20 off-year.
It may well mean that they have a partial, or 21 a component exercise in that off-year.
It is more than 22 just a table-top protective action decision-making 23 process.
24 I guess our discussion with Brian about 25 clarification of that is just to make sure that there is ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202).554 2345
31 I a good understanding of States and locals as to'what the 2 rule is going to mean.
As I have discussed it with
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3: people, I think there was a feeling on their part that 4 this means, we are only going to have to exercise every 6 other year, and we want to be sure that.there is a good
- 6. understanding that this may well not be the case.
7 I guess, in talking with our regional people, 8 ve feel that this would clarify.
It would give us what 9 ve think is quality control over those exercises, the 10 ability to really pinpoint and work through some of the 11 problems identified in each full-scale exercise.
12 CHAIRMAN PALLADINO.
To what extent does the 13 experience gained with other natural disasters, or 14 accidents, contribute to the exercise of emergency 15 planning-for nuclear power plants?
16 HR. THOMASa There is a considerable amount of 17 transferability, particularly in the direction and 18 con trol components, evacua tion components.
As an 19 example, I directed operations in hurricanes, I directed 20 operations in civil disorders, and I found a 21 considerable amount of tranferability in the state 22 between.those operations and the nuclear power plant 23 exercises f or one reason, it was generally the cast of 24 characters in both.
25 In other words, in my command center, the s
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1 Director of State Police and State Highway Patrol were 2 the same people who-were there when we had a. hurricane
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3 or a nuclear power plant exercise.
The State Directors 4 of State Emergency Services were the same.
There is a 5 good bit of. transf erability.
6 CHAIRMAN PALLADINO:
The reason I raise the T question is that I received a copy of the. letter that 8 vent to Mr. Grimes from Erie Jones, and he says:
"To 9 give you some perspective of the frequency of 10 occurrence," he is triking other disaster, "let me tell 11 rou. that during 1981, Illinois Emergency Services and 12 Disaster Agency responded to 2437 incidents, many of' 13 which required significant response, including the
(
14 movement of people during emergencies. that might cause 15-injury to individuals if they were not. evacuated from 16 their homes. "
17 That sounds to me like our emergency people 18 are not just sitting there waiting for something from a 19 nuclear power plant to happen, but rather are very 20 active. group responding to a variety of emergencies.
21 While I know they don't necessarily follow the same kind 22 o f plan, if there are actions that are transferable to 23 the nuclear emergencies, then this is almost a 24 continuous exercise of some portion.
m_;
25 NR. THOMAS:
Of some portions of it, and I ALDERSoN REPCRTING COMPANY,INC.
400 VIRGIN!A AVE., S.W., WASHINGTON. D.C. 20024 (202).554-2345
33 I'
1 think that is the feeling we have about why it is so 2 important to think in terms of the components that you
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3 vant to exercise.
You, obviously, are not. exercising 4 your radiological health component and dosage 5 requirements'in some of the natural disasters, but you 6 are definitely exercising your other components, 7 'particular1r direction and control, communications 8 components, and evacuation components.
9 I would really lend support to some of the to things that Erie Jones is saying in Illinois.
11 CHAIRMAN PALLADINO:
You were going to 12 con tinue down this slide.
13 MR. THOMAS:
One final thing that had been 14 discussed earlier that we vanted to comment on, and that 15 is, as we revise our rule, one of the. things that we I
i 16 vant to incorporate is additional language concerning r
l 17 Federal participation at each site.
l l
18 In the proposed rule, Federal participation 19 will be required.
There will be, as Brian said, the 20 capability or provision for Federal participation at 21 each site every seven years, which we feel there should 22 b e.
We would like to see, in our rule, under authority 23 to coordinate Federal response, some language to require 24 Federal participation at each site, and in each state, 25 on a regular basis.
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1 We are working with your staff, talking in 2 terms of what an adequate time-f rame maybe, but the idea
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3 would be to try to exercise, say, for instance, each of
-J 4 our regional offices on a regular basis in the states, 5 to ensure that-there is a good meshing between.the 6 Federal resources and the Federal response, and the 7 SIate sud local and licensee's response.
8 CHAIRMAN PALLADIN0s This would take place at
& the same time that - the State is f ulfilling its-f ull 10 responsibility at each site.
11 MR. TE0HAS:
That is correct.
12 CHAIRMAN PALLADIN0s At least once every seven
( -
13 years.
14 MR. THOMAS:
That is correct.
15 CHAIRMAN PALLADINos Is there is a state Slat 16 has only one site, would the provisions be where would 17 only participate every seven. years?
18 MR. THOMAsa No, that is a dicussion that we 19 need to work out, what an appropriate timeframe would be 20 in which the Feds participate in that state.
I think it 21 c.ught to be more frequently than seven years.
The 21 Federal agencies should actually respond and participate 23 in each state en a more frequent basis than that.
kJ 24 MR. GRIMES:
This is something that we would 25 have to look at where it belongs.
It may be more
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'rm 1 appropriate, under FEM A 's authority, to have this in the 2 FEMA rule than in the NBC rule.
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3 HR. THOMAS:
That was our point.
We want to 4 try to include in our rule some language under our 5 authorities. to coordinate that Federal response that 6 requires and ensures a frequent interaction of.those 7 Federal, State and local agencies.
8 CORNISSIONER ROBERTS:
Can you give me a 9 definition of table-top protective action 10 decision-making drill?
11 MR. THOMASa-What that basically is, the 12 appropriate State officials have an exercise, not a 13 field exercise where they are actually going through a 14 scenario carrying out roadblocks, but where you exercise
- 15. with simulated events,. where the scenario calls for
- 16. various information coming into the headquarters and the 17 individual of that State agency who responsible, 18 indicates what action his agency would take a t. tha t 19 point, " Based on this information, we would do these 2a things."
21 It is a decision-making.
It is to determine 22 if each of the decision-makers in appropriate agencies 23 are adequately prepared to respond to the actions that
- 24. vould be required.
They are useful exercises.
We have 25 them.
For instance, for our full-scale field exercise, ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554 2345
36 1 we have a table-top exercise several times with the 2 State and local agencies in preparation f or a f ull-scale 3 field exercise.
4 CHAIRMAN PALLADIN0s.
Do you have more?
MR. THOMASa-No, sir.
Tha t, basically, I E
6 think, is the position we would recommend on it, and we 7 would like an opportunity to work with your. staff on the 8:languge that we have been talking about with them, and 9 proceed.
10 As I indicated our 350 rule, we hope to get in 11 final form for publication in the Spring.
The reason 12 that we haven't proceeded with it prior to now was the 13 process we have been going through for the last number 14 of months with your Commission, to ensure that we are 15 consistent on the components.
16 COMMISSIONER GIIINSKY:
Do our rules cover 17 this?
How does the system work?
I must say I am a 18 little bit unclear.
If you changed the rule, would that 19 do it, is that all there is to it, or what?
20-MR. GRIMES:
Our rules are binding on our 21 licensees, of course.
FEMA has a proposed rule in place 22 which has no binding effect on States and locals.
23 COMMISSIONER GILINSKIa Covering th ese
- 24. points?
25 MR. GRIMES:
It gives guidance covering these
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1 same points.
Right now the FEHA proposed rule is 2 consistent with our in-place rule.
They are looking at 3 putting their rule in final, but before they do that,
{3 4 they would like to make sure that we have a. consistent 5 rule-on the NBC side.
6 MR. TH0HASs.
Your rule really deals with 7 licensees.
Our rule, which is consistent with your 8 rule, deals with the plan'ning component that the State 9 and loca3.s are required to submit to us in the planning 10 and exercising of that plan.
11 COMMISSIONER GILINSKY:
Does our rule 12 incorporate your rule?
(.
13 HR. THCHAS:
No.
14 COMMISSIONER AHEARNE:
If you say that ther 15 are required, it is binding in a sense.
In-what way is 16 it a requirement, is it binding in what sense?
In what 17 vay is it a requirement?
18 HR. THOMAS:
The existing rule th a t we ha ve,
19 that is out, is guidance to States and locals in their 20 planning process for off-site preparedness.
21 COMMISSIONER ROBERTS:
Is your new rule in the 22 Spring going to be binding?
23 HR. THOMAS:
Our General Counsel's Office has 24 proposed that it would be a rule that would cover and be s
25 binding on approval of a state plan for off-site m
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1 preparedness.
2 COMMISSIONER AHEARNE:
In other words, in
{i 3 order for you to approve a state plan, they must do 4 these things, but there is no requirement f rom FEMA that 5 there be an approved: state plan.
6 HR. THOMASt The requirement is f rom you. that 7.ve provide you findings on a state plan, so that is 8 where the issue has come about, whether it is guidance, 9 or whether it is binding.
That is the issue between 10 your rule and our guidance.
11 COMMISSIONER GILINSKY:
Where does the 12 one-year or two-year business show up, in your rule or 13 in our rule?
(' ' ~
14 HR. THOMAS:
Both,.your rule and our 15 guidance.
16 CHAIRMAN PALLADINO:
They ought to be 17 consistent.
18 HR. THOMAS:
Yes.
19 COMMISSIONER GILINSKY:
Do we have a proposed l
20 rule on. this, or are you proposing it to us?
2t FR.~ GRIMES ' We are proposing it to you.
We 22 have a actual rule which the FEM A proposed rule is i
23 consistent with.
We would like to change our rule by 24 putting out a proposed change to that rule.
Then when 25 that is finally approved, FEMA would change its rule to l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W. WASHINGTON, D.C. 20024(202).554-2345
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39 I
1 1 exactly conform to that, so we would be consistent.
2 For exampic, right now, FEMA has modified its el 3 proposed rule so that it reflects exactly the wording of 4 our planning standards in the regulations.
I think the 5 language on the exercises will be slightly different 6 because ours lays a requirement on licensees to 7 demonstrate that certain things are done, and theirs 8 would be conditions for approval and continuing approval 9 of state plans.
10 COMMISSIONEB GILINSKY Can I ask you on what 11 basis you proposed the original relaxation of these 12 requirements?
13 HR. GRIMES:
First of all, I think the
~
14 principle from FEMA, and as also reflected in a meeting
- 15. with Chairman Guiffrida and Chairman Palladino that this 16 exercise frequency should be looked at.
Then on th a t 17 basis, we developed a scheme which we then provided to 18 FEM A, and worked with them.
Then we went over and 19 worked in detail with the IOAC, not in the exact final 20: words here, but the same charts, for example, on the 21 exercises for a state, for the partials, an d th e 22 definitions.
23 We went through that and got a consensus on 24 what the appropriate approach was, and then we proposed 25 to change our rule, since it was the one that is in ALDERSON REPORTING COMPANY,INC, 400 VIRGlNIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554 2345
40 e-1 place.
2 CHAIBHAN PALLADINO:
I remember at the meeting
('"
3 we had, where General Gulffrida was present and others, 4 there vere reports that the tremendous on individual 5 counties and individual areas, as well as the State, and 6 the frequency with which they had to participate was far T greater than would be implied by.just once every-year.
8 It seemed that some-of the counties.were involved every 9 time you turned around.
I don't have the details on 10 that.
11 NH. GRINES:
There were some particular 12 impacts, I think, on places that are affected by more 13 than one f acility.
For example, Grundy County, for i
~
14 example, is affected by both LaSalle and Dresden.
15 CONNISSIONER AHEARNE:
Which would mean it 16 would have to participate in all of them.
17 CHAIRMAN PALLADINO:
Under the present rules, 18 r es.
19 MR. GRIMES:
Under the present rules, it would 20 have to participate with each site each year.
21 COHNISSIONER AHEARNE:
So it would have to io 22 twice the work.
l MH. GRIMES:
Yes.
In preparing for this, 23
(
24 there were additional exercises done to develop the i
25 Illinois State plan, and that was extra also on them.
1 ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W WASHINGTON, D.C. 20024 (202).554-2345
41 I-1 Then there was a problem with one of the exercises at 2 LaSalle, which was then resolved by having an exercise 3 within four months at Dresden, and allowing the county 4 to exercise that.
E COMMISSIONER GILINSKY:
You are responding to 8 these concerns, or expressions?
7 CHAIRMAN PALLADINO:
He did not say that, but 8 I felt that those contributed to it.
I think we should 9 be sensitive to those problems.
10 COMMISSIONER GILINSKY:
Yes, I am just trying 11 to understand what it is that is going into the pot
- 12. h ere.
13 MR. THOMAS:
That is part of the background of
(.~
14 1t.
I think, for instance, Mr. Godwin and the IOAC have 15 spoken to that, as Erie Jones has spoken to it in.his 18 letter.
17 COMMISSIONER GILINSKY:
Can I ask Brian just 18 one more question.
l 19 Did you literally mean the sentence you put in 20 your meno, "The NRC does not have expertise in off-site 21-energency preparedness"?
l 22 MR. GRIMES:
I think perhaps that is too
(
23 strong, since we do have memories of our regional
([.
24 offices.
25 COMMISSIONER GILINSKY4 Since you have
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1 recommended a major change in this proposal.
2 MR. GRIMES:
We have responsibility to
(^N 3 overview it, so we have general knowledge, but we don't 4 have the detailed day-to-day working knowledge.
That 5 would be a-better way to put it.
We do have the 6 contributed expertise of our regional offices through 7 reviews of the health physics parts of the state plans, 8 and things like that.
9 We do, at headquarters, have an overview just to by experience with exercises, and looking at interfaces 11 with this sort of thing.
So perhaps t. hat statement is 12 too strong, and should be drawn more in terms of, we'do r.
13 not have the intimate day-to-day knowledge that FEMA 14 does in this area.
15 I think we hope to rely more and more on FEMA 16 in this area, and essentially turn over to FEMA some of 17 the areas we have been working on like the evacuation 18 time estimates.
19 CHAIRMAN PALLADINO:
We look to FEMA to guide 20 in the individual emergency plans, and to deve3 1 21 emergency plans, overseeing the exercises, and giving us 22 the recommendations as to whether the plans are any good 23 o r no t.
It would seem to me that relying on them for 24 those things should cause us also to rely-on them for v
25 their guidance on the f requency.
N
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COHNISSIONEB GIIINSKY:
Except in this case 2 that initiative seems to have come from us, FEMA
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3 highlighted it.
4 CHAIRMAN PALlADINO:
I did not get. that.
I 5 thought FEHA clarified that.
6 COMMISSIONER GILINSKY:
FEMA clarified it as 7 an issue, b'ut it looks like the two-year-business is 8 something that we came up with.
9 MR. THOMAS:
We highlighted it as an 10 initiation in a joint meeting.
It was one of the issues 11 that we brought forward that we felt needed to be 12 reviewed.
13 The backgrcund
'.s that we want'ed to ensure s
14 that your rule and what ve. vere doing was consistent.
15 Therefore, we recommended that we work jointly on 16 several things.
One we felt that needed to be worked on 17 as frequency of exercise.
18 COMMISSIONER AHEARNE:
By being worked, what 19 did you have in mind?
20 MH. THOMAS:
We felt the existing rule that i
21 was in place was not completely workable.
It was 22 requiring too much, too many exercises in some places.
23 Brj an and his staff took a cut at what they felt was a l
24 move on it, and then we worked on that draf t, and came 25 back and forth, and we worked jointly, and we worked
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44 I~'
1 with IOAC.
2 COMMISSIONER AHEARNE:
Was Illinois the main r
3 area of problem, or is it that we have been requiring m
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4 too many exercises in some places?
5 MR GODWIN:
Illinois is certainly not the 6 or < problem.
Actually, Alabama doesn't show fully ~what 7 we have done.
We got brought into at least one other 8 plant's ingestion pathway, and we had to also exercise 9 there.
So within really.a one year period of time, we 10 have had actually three exercises, which fell within a 11 one year timeframe.
12 It does make a significant impact where you 13 have multiple siter impacting on the State and the local
(
14 counties.
The State, I might add, is probabir more
'~
15 affected really than the counties in number, because 16 virtually anything that happens, ends up that you have 17 to activate your dose assessment group and your 18 decision-making group, and tha t is almost 100 percent 19 for any kind of exercise you come up with, unless it is 20 going to be extremely limited.
21 COMMISSIONER GIIINSKY:
Isn't that the very 22 area where the states have been weak, which is unique, 23 and which isn 't exercised in other sorts of disasters 24 such as earthquakes?
25 MR. GODWIN:
I don't know that that is ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554 2345
45
T 1 altogether true..
I think they are coming up pretty well 2 with it.
The problems I see are that we are getting 3 hidebound to procedures, and we really ought to be 4 looking more at what is going on and what is really 5 happening, and make sure that we keep in mind that the 6 procedures are basically a guidance and not.something 7 tha t:. you are locked into absolutely.
8 You can be waiting events, a prime example is 9 the site area emergency, and you can have discharges to that would exceed P AGs out, and you re>1ly need to take 11 some sort of protective actions beyond the plant site.
12 It is a rare occurrence, but you can 't predict those',
13 and somebody needs to make sure that you don't get too i
14 locked in on procedural matters.
15 COMMISSIONER GIIINSKY:
I am not sure I 18 understand you.
Are you saying, we don't look at cases 17 which exceed the P AGs?
18 HR. GODWIN:
No, I said, you have cases under 19 the site area emergency, if you look literally at the 20 criteria, that you could project a dose beyond the site 21 boundaries that would exceed PAGs, and someone should 22 take a protective action.
The connotation is that you 23 may not have to --
s 24 COMMISSIONER GILINSKY:
I am not sure whether 25 you are saying that the procedures are keeping you f rom ALDERSON REPORTING COMPANY,INC.
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46 O-1 looking at those cases?
2 MR. GODWIN:
I am saying, let's make sure that
(
3 the people that are doing the decision-making and doing 4 these procedures recognize that there are limits on what 5 they should follow in the way of procedures, and ther 6 should keep their eyes open and make sure that we don't 7 practice and practice and practice so that. the 8 procedures become almost a Bible that you have got to 9 follow.
10 I see this coming with so many exercises.
You 11 go down this list, and it has got to follow that list.
12 If it doesn 't follow that list, you know, you are in 13 trouble.
The reactor doesn 't read yo ur. list, so let's
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14 follow what is going on at the reactor.
15 COMMISSIONER GILINSKY:
What you say sounds 16 right.
17 MR. GODWINs 5 am especially concerned tha t if 18 you exercise a lot following a list, people will get 19 tha t burned in that they have to follow the list, and 20 will not recognize or cease to recognize, because they 21 have done it so many times, that they have got to think 22 and not follow a list.
23 COMMISSIONER GILINSKI:
It sounds like the 24 list is not quite what it ought to be.
25 MR. GODWIN:
I am not sure that you can come c
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.47 1 up with one that is totally inclusive.
2 CHAIRMAN PA1LADINO:
There are a variety of r~s 3 iays to proceed.
One that we might consider here for 4 the moment is to ask Brian Grimes to go back and 5 introduce this new variation into your paper, and 6 present it for the Commission action.
7 I would suggest that unless the Commission 8 feels that this is another waste of time, and we are 9 going to stay where we are.-
It would be my 10 recommendation that the revised wording get in there, 11 and any of the other changes that were talked about 12 here.
13 MR. GRIMES :
Before we make closure on that, 14 Nr. Godwin did have a short prepared presentation.
15 CHAIRMAN.PALLADINO:
I am sorry.
16 MR. GODWIN:
You were asking questions, and I 17 was just trying to respond to the questions.
18 CHAIRMAN PALLADIN04 I assumed that everybody 19 was finished, I am sorry.
20 MR. GODWIN:
I do wish to thank you all for 21 inviting us to appear.
Mr. Jones could not appear, as 22 you see from his letter, and he sends his apologies.
I 23 vill. keep my remarks real brief.
24 As has already been indicated, many of the 25 evacuation plans are common-type plans in the basic ALDERSON REPORTING COMPANY,INC.
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48
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1 concepts of control, personnel.
It really doesn't 2 natter if it is a nuclear plant, or chemical, or other
)
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3 matters, you are using the same people, although you may 4 be telling them to go to a little different area for 5 different ones, but'it is basically the same. approach.
6 Secondly, based upon what ve have had in the 7 exercises we have had with our plants prior. to the nev 8 rule, we found that we could, in fact, go be k after a 9 year or two, and there was pretty good retention of 10 knowledge about what was in the plan.
We found that 11 this is true in Alabama, and I suspect that it is true 12 in other areas.
13 As I alluded to a while ago, we should always
~.
14 make sure that we don't get to following the cookbook, 15 if you would, and keep our eye following the problem 16 around the cookbook.
In fact, we try to really stress 17 that the plan runs for six hours, and af ter that you 18 should have people in place that can follow what is 19 going on.
You should not try to cookbook beyond six 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.
This, I think, helps.
We do need sor.e real 21 interest information.
22 We support the comments that were made 23 regarding the Federal agencies.
We have not seen real 24 strong participation from Federal agencies, with two 25 Federal agency exception, those being NBC and FEMA.
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1 They have participated to a degree in Alabama, and ther
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2 have participated even more in other states.
3 Unfortunately, other agencies are not 4 participating as much as most of the states, I think, E would like to see.
They see some real concerns arising 6 out of being.just tota 117 demolished by the influx of 7 Feds, to be honest about it, and they want. to see what 8 is going to happen.
Will the Federal government 9 respond, do they have their act to ge th er.
10 COMMISSIONER AHEARNE:
What are those 11 agencies?
12 MR. GODWIN:
DOE, EPA, HHS, those are the main 13 ones.
(' ' ~
14 COMMISSIONER AHEARNE:
Commerce?
15 HR. GODWIN:
Congress?
16 COMMISSIONER AHEARNE:
Probably.
17 MR. GODWIN:
Probably, you can name a whole 18 slev of them.
19 CONHISSIONER GIIINSKY Congress migh t be more 20 interesting.
2t NR. THOMAS:
In that regard, I might comment, 22 that it has been something that we have been actively 23 pursuing.
FEMA's delegated responsibility for
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24 coordinating Federal response and ~ the master plan for 25 radAological response at the Federal, is one that we ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554 2345
50 1 have been putting in final form.
We are talking in 2 terms of a series of exercises to include the full
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3 Federal family, not just FEMA and NRC components.
4 This is something that we are working actively 5 on with a series of agencies, and you are. talking about 6' agencies such as the Department of Agriculture, and the 7 Department of Energr, and the Environmental Protection 8 Agency.
Those kinds of agencies are the ones who would 9 play a role and have an active role in any kind of a 10 major emergency.
11 COMMISSIONER AHEARNE:
Certainly DOE and EPA, 12 in any real emergency, we have had to have immcdiata' 13 recourse to them.
(
14 HR. THOMAS 4 That is correct.
You would be 15 amazed at the number of resources that are available 18 that we would call upon in agencies you would not 17 immediately think of, such as HUD, the available housing 18 units in a particular area if we had to evacuate, those
- 19. kin ds of tr ings, the Department of Military Support, a 20 whole range of military support capabilities.
21 In emergencies that we are involved in, 22 disasters that we are involved in on an active basis all 23 the time, we call on a full range of Federal agencies to
(_
24 provide support to State and local units of government.
25 That is the same kind of process we are working on in ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W WASHINGTON, D.C. 20024 (202).554 2345
4 51 t'r 1 this kind of activity.
2 MR. GODWIN:
Just one last commen t.
We see
(])
3 difficulties in the RACS being able to physically get 4 around and review exercises.
There is a ;cheduling 5 probice from that point of view, and. there is just a 8 physical impossibility for.them to get around and do 7 their review.
8 COHNISSIONER B0BERTS:
What is your acronym, 9 RAC7 10 MR. GODWINt Regional Advisory Committees.
11 NR. THOMASt Regional Advisory Committees of 12 the Committee of the Federal Agencies at the regional 13 level chaired by FEMA that reviews the plans and 14 participa'te in the review of the exercises.
15 MR. GODWINt Just a couple more. comments, if I 16 m ay, Mr. Chairman.
17 I would again stress the point that even 18 though you may be having a local drill, it almost 19 invariably means that you are going to have 100 percent 20 dose assessment and direction control activated at the 21-Sta ce level, and usually all of your notification part.
22 COMMISSIONER GILINSKYa But isn't that good?
23 NR. GODWIN:
Well, you can activate for some 24 many things that it begins to get 25 CONHISSIONER GILINSKYs The dose assessment?
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52 I'd 1
MR. GODWINa We have a lot of training that we 2 do alsc, you see.
We do try to keep in my shop, and I
('3 3 know other s tates do too -- I am not saying that ther 4 all do, of course, but I am saying~that those that are 5' pretty active in it,.do try to keep their staff capable 6 of doing dose assessment.
They have pretty good 7 responsibility.
8 COMMISSIONER GILINSKYa But isn 'ti this a a terrific way of doing that?
10 MR. GODWINs It is not as good.
It becomes 11 more of a game in trying to check off the list, rather 12 than really 13 COMMISSIONER GILINSKY:
What is wrong with the
(
14 list.
If all of this is being done in a miniless way, 15 and you are saying, the less you do it, the better, that 16 is really not a very good thing to be doing.
Then, we 17 are doing something very wrong, and we have got to go l
18 back to square one and revise our procedures.
19 CHAIRMAN PALLADIN0s It is a little bit like 20 having a fire drill every week.
Then, when it. happens, 21 You say, "Oh, it is just one of our weekly drills," and 22 you just think of it in that term, rather than "maybe it 23 is the true thing."
24 MR. GRIMES:
I think there is a distinction l
25 also between the training drills where people are ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554 2345
53 f~ N, 1 assisted through and monitored by their own peers within 2 the state, and the same thing is true for licensee 3 drills, and an observed exercise where everyone is put 4 to a test, and the object is not to improve skills --
5 COMMISSIONER GILINSKYa Isn't the problem just 6.the opposite one, if it is in-house if you keep it 7 within this little group, you can lapse into a' routine, 8 you are not as tough on yourself as you would be if you 9.had to face a test or something.
10 MR. GRIMES:
You have a mix.
11 MR. GODWIN:
This is one you have to mix.
12 First of a13, the given that it starts out with, you' 13 have a vorking group that has demonstrated its
(
1& capability through an exercise, which has already 15 demonstrated that they can do the job.
That is the 16 given before you gave the license, presumably, at this 17 stage.
18 COMMISSIONER GILINSKYa But we are checking it 19 here.
20 MR. GODWIN:
What we are doing now is, how do 21 you want to check it?
That is really what you are 22 looking at, how do you want to check to see that it 23 still works.
24 COMMISSIONER GILINSKY:
Right.
It is not just 25 a matter of ' checking, of FEMA coming in and giving you a
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54 x
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1 grade.
It is a matter of all of us checking, 2 participating in an exercise that we are all keeping
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3 everything well-oiled and greased, and we are ready to
& go, and so on.
E NR. GODWINt It is not really that simple.
6 With mT staff, I can work up a series of problems, and 7 valk through them in one or two days.
8 If I am going to have an exercise that is 9-reviewed by FEMA, I have got to start three to four 10 months in advance to get all of my givens developed.
I 11 have to come up with State observers, and Then FEMA is 12 going to be there observing me.
We will go through all 13 of this, and this is just for a small drill now, if they 14 are going to come in and observe, I have got to do all 15 of this.
16 You are talking about going from one to two 17 days of training that I specifically want to review, to 18 a whole series of things, including how much equipment I 19 may have requested f rom DCE, did I request it soon 20 enough, did I have decals on the cars, these kinds of 21 things.
(
22 COHNISSIONER GILINSKYa The feeling I am 23 getting out of this is that we really ought to focus on k
24 j us t wh a t the se d rills a re lik e.
t 25 HR. GODWIN:
I would invite you to come down l
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1 and join in one.
2 COMMISSIONER GILINSKY:
I will.
I don't know
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3 whether I can get to Alabama.
4 MR. THOMAS:
I think that, basically, though, 5 is, I guess, the basis of our recommendation, and tha t 6~ is-that we ere trying to focus on what the drills are as 7 opposed to the frequency of the drills, the substance of 8 the drills..
COMMISSIONER GILINSKY I guess, from the 10 reaction I hear on maintaining the frequency of drills, 11 I wonder whether the drills are what they ought to be, 12 or are the kinds of drills one wants.
13 MR. THOMAS:
When you are talking about a
- 14. f ull-scale drill, and you are going to test the 15 capability of those State and local units of government 16 to respond to an incident, it is full-scale.
It is t 17 full simulation of what would be required, and it 18 requires a considerable amount of resources -- people, 19 dollars, and everything else, to get in the field.
20 MR. GODWIN :
The last round of exercise, we 21-fielded right around a thousand people for essentially a 22 day-and-a-half.
23 MR. THOMAS:
So there is a considerable amount 24 of planning that goes on in getting those thousands of 25 people ready to participate.
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1 COMMISSIONER GILINSKYa I guess I don't think 2 that reducing the frequency of drills --
3 CHAIRMAN PALLADIN0s But we are addressing
(}
4 frequency here.
It doesn't mean that.the substance is 5 not.being addressed, because that was another one of the 6 items that was discussed when we met jointly with FEMA 7 and NRC.
8 MR. GRIMES I would also note that if any of 9 the Commissioners would like to observe an exercise, 10 there are a number that are happening this month, and 11 about 10 in March.
There may not be that many again for 12 a while, because everyone has tried to get the initial 13 exercise done.
So it is a good opportunity,
(
Certainly, I 14 particularly in March, to pick a site.
1S^ would encourage you to go and observe an exercise.
16 COMMISSIONER GILINSKY:
Does that complete 17 your presentation?
18 MR. GODWINa Yes, and I appreciate it.
19 COMMISSIONER GILINSKY:
I was going to 20 suggest, Joe, that you,ask Brian to rewrite it.
I would 21 recommend, if you do want to modify the current state of i
22 affairs to do it in a way that would relieve a State of 23 the need to exercise the plan if FEMA gives them a 24 suf ficiently good report, let's put it that way.
25 CHATRhiN PALLADINO:
I think I would like to 1
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1 see some-input on that.
I look to FEMA as the lead 2 agency, the agency that has the most expertise on this p
3 type of activity.
If we are going to rely on their w
s 4 judgr.ont on the substance of the reviews of the 5 exercises, I think we should certainly rely on their S.Sudgment on the frequency and the substance.
I am not 7 saying that. ve should not. have our independent 8 thoughts.
9 I. think that that is an idea that. has a lot of 10 merit, and it may be something that we want to look at 11 and see if you continue to find merit when you look at 12 it.
(_
13 Do I gather that it would be agreeable to the 14 Commission to have a rewrite of this paper and 15 resubmittal to the Commission, including any individual 16 comments Commissioners may have on the last paper? ~Do 17 you see any problem in proceeding that way?
18 COHNISSIONER AHEARNE:
As I have mentioned, I
- 19. vould support backing off to Vic's position, but-that is 20 as far as I can go at the present. time.
2r COHNISSIONER GILINSKYa I must say I am not 22 uncomfortable with where we are righ t now.
23 COMMISSIONER AHEARNE:
I will agree, in 24 general with your reint, Joe.
However, in this 25 situation, I gues -- a ming of my past experience in other s
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58 1 agencies vf.th exercises, I can recall many tim es. man y 2 military organizations complaining bitterly about the r ';
3 length of time it.took, and the effort that it took to 4 go through the exercises..
It was just so hard to do it, 5 but unfortunately, until. you go through it several 6 times, it just doesn't shake out.
7 I know in those places that I saw, and 8 continued to see, and I have seen here, it is going E through those exercises that problems you don't 10 recognize, that you can't possibly believe are there, 11 shake out.
12 I would prefer to keep it for another couple 13 of years as we have it, but I am willing to back off to 14 the point that Vic has said.
15 CHAIENAN P ALLADIN0 s But there is an 16 implication there that we are not exercising.
17 COHNISSIONER AHEARNEs No.
18 CHAIBMAN PALLADIN0s We are exercising.
19 COE5ISSIONER AHEARNE:
I understand that, we 20 are exercising.
The implication is that for many years 21 there was no off-site emergency radiological exercises.
22 It is the last few years that has brought about this 23 change, and I would be much more comfortable with a 24 little more experience in shaking out, but I as willing 25 to' go with Vic 's proposal.
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MR. CRIMES:
Would it be useful for us to 2 prepare a formulation in both ways.
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3 CHAIRMAN PALLADINO:
It migh t be.
4 COMMISSIONER GILINSKY:
Both ways being what, 5 now?
6 NR. GRIMES:
One along t.
- lines we have 7 discussed this morning, and the other along the lines of 8 requiring it every year, with exceptions when FEMA 9 provides a favorable finding, and laying out those two 10 alternatives before the Commission.
11 COMMISSIONER GILINSKYs Would you ask the 12 regional administrators, too, in detail.
13 MR. GRIMES:
We are talking to their staff at 14~this time.
15 CHAIRMAN PALLADINO:
General Counsel has a i
18 point.
17 MR.'BICKWIT Throughout the development and 18 implemantation of this rule, we have had all the safety 19 judgments made by the NRC.
Those safety judgments, 20 admittedly, have been based on FEM A's finding.
If you 27 are now talking about a FEMA finding that is going to be 22 dispositive, that is a change from the normal way.that 23.we have been doing business.
It creates a possible 24 legal. problem.
I would prefei-to be consistent with the 25 way we have been doing it, which is to have FEMA make a
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60 It 1 these findings, and then te have NRC make the final 2 judgment based on those findings.
3 MR. GRIMES:
We vill certainly work with the
( ],
4 Office of General Counsel on this.
5 CHAIRMAN PALLADINO:
Where does the problem 6 arise?
7 MR. BICKWIT:?
The conceivable problem is that 8 NRC has health and safety responsibility in licensing 9 these plants.
The question is, can it completely 10 delegate any part of.that function to another agency.
11 The answer is not entirely clear, and we have tried to 12 avoid reaching that question by ensure that the NRC does 13 not totally delegate anything.
Whenever health and
'~'
14 safety judgments are made, the NRC bases its. judgment on 15 the FEM A findings, but it is the NRC's judgment.
16 CHAIRMAN PALLADINO:
Are you saying that 17 changing the frequency affects that?
18 MR. BICKWITs I as saying that in the 19 formulation of this proposal, where you would dispense 20 with the annual requirement only when FEMA makes a 21 finding of a good mark, giving a good mark to the State, 22 that is a departure from the way we have been doing 23 business.
24 I would suggest, if we are going th a t way, 25 FEMA should make that finding, and NRC should base its
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1 finding on that finding.
2 COMMISSIONER AHEARNE:.In other words, you are 3 saying that the NRC should then relieve it based upon 4 the FEMA finding.
5 NH. BICKWIT:
Based upon the FEMA finding.
6 CHAIRMAN PALLADINO:
Not having the complete 7 sense of the feeling of the Commission, I think it may a be worthwhile to write it both ways.
9 COMMISSIONER GILINSKY:
We could also 10 introduce John's modification, which is that this would 11 come into play two or three years from now.
12 CHAIRMAN PALLADINO:
What would come into 13 play, the good mark?
14 COHNISSIONER GILINSKY This system of it relaxing the one year annual exercise, after we have 16 developed some experience.
17 CHAIRMAN PALLADINO:
I got some indica tion 18 earlier that FEMA was f ar stronger on this point than I 19 f elt this morning.
20 (General laughter.)
CHAIENAN PALLADINOL I really think it is 21 22 important to stress this, because I think it has an 23 impact on the issue.
I heard that FEM A is coing to go 24 ahead and put this in their regulation, even if we 25 did n ' t, that is how strongly it felt.
I take that only
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I) 1 as an expression of your feeling, not of your' intent.
2 Is this a FEM A recommendation, the one that 3 you propose?
4 ER. THOMAS:
Maybe I have not been strong 5 enough.
6 (General laughter.)
7 HB. THOMAS:
Haybe I am just too pleasant a 8 fellow.
9 FEMA does feel very strongly about.it, and
- 10. FEM A certainly supports the statement you made that you 11 have relied on us and do rely on us to give you the 12 findings on of f-s'ite preparedness.
We would hope, then, 13 that you would rely on us and consider us competent. to
/
14 give recommendations on frequency of reviewing off-site 15 preparedness.
We understand, however, your 16 responsibilities for health and safety, I think, as your 17 General Counsel noted, as f ar as the licensee is 18 concerned.
19 We do plan to issue our guidance to State and 20 locals, and we do hope that it is consistent with your 21 rules.
I think it would be terrible for us to have 22 conflicting guidance there.
I don't want to sit here i
23 today and bring us to some impass in that regard, but we 24 feel extremely strongly that it is our proper role to 25 recommend to you in this area.
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1 COMMISSIONER AHEABNE:
I don't mean in any way 2 to imply that I am not interested in the subject, but I f';
3 am committed to leave.
4 CHAIBHAN PALLADINO:
Can.ve agree that Brian 5 is going to write up both points of view, and this will 6 give us an opportunity to understand this better.
7 Is there anything further on this question?
8 (No response.)
9 CHAIRHAN PALLADIN0s If not, thank you for 10 coming.
We appreciate your input.
11 We stand adjourned.
12 (Whereupon, at 11:25 a.m.,
the Commission 13 adjourned, to reconvene at the call of the Chair.)
tL-15 16 17 18 19
.20 21 22 23 v
24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554 2345
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p-NUCLEAR REGULATORY CO.5dMISSION This is to certify that the attached proceedings before the
-(
COMMISSION MEETING in the matter of: PUBLIC MEETING - FEMA PRESENTATION ON RULEMAKING ON FREQUENCY OF EXERCISES Date of Proceeding:
February 4, 1982 Docket llumber:
Place of Proceeding:
Washington, D. C.
were held as herein appears, and that this is the original transcript thereof for the file of the Commission.,
Patricia A. Minson Official Reporter (Typed)
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1/5/74 P
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Attached.are] copies of a Cor:: mission meeting P
transcript /s/ and related meeting document /s~/.
They are being forwarded for entry on the Daily Accession b
List and placement in the Public Document Room.
No 10) other distribution is requested or required.
Existing DOS identification numbers are. listed on the individual documents wherever }nown.
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SCHEDULING NOTES FOR COMMISSION MEETING WITH FEMA ON RULEMAKING ON FREQUENCY OF EXERCISES Scheduled:
10:00 a.m.,
Thursday, February 4, 1982.
Duration:
1-1/2 hours.
Purpose:
To discuss FEMA position on emergency planning exercises.
Participants:
1.
Brian Grimes, IE (Intro) 2.
Lee Thomas, Associate Director for State & Local Programs and Support, FEMA 3.
Dick Krimm, Ass't Associate Director for State & Local Programs and Support, FEMA 4.
Aubrey Godwin, Director, Division of
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Radiological Health, State Department of Public Hcalth, Alabama (see 1/25 letter to NP)
Also attending:
William Dircks, ED0 Richard DeYoung, IE
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EXERCISE ACTIVITY NO. OF SITES
- STATES WITHIN 10 MILE EPZ EXERCISES COMPLETED EXERCISES SCllEDULED" 7
ILL 5
0 6
SC, NY 9
4 WI 5
MI, PA 7
6 TN 4
4 3
CA, FL, 11 4
GA,MS,My,LA 2
M 1
1 n"<
DE, WV GM E dei 55 N89 "F ie P*
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Includes operating plants and those under construction
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- Through 4/1/82 x
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- OF EXERCISES TODATE STATE
- PARTICIPATED IN FACILITY EXERCISED Maine 1
Maine Yankee New Jersey 1
Salem Delawcre 1
Salem New York 2
Nine Mile Pt. Ginna Pennsylvania 1
N. Anna, Surry Maryland 1
Calvert Cliffs Tennessee 2
Sequoyah(2) 3 Georgia 3
Hatch (2), Farley Alabama 2
Browns Ferry, Farley North Carolina 2
McGuire, Brunswick South Carolina 2
Robinson, Summer Mississippi 1
Grand Gulf Louisiana 1
Grand Gulf Ohio 2
Zimmer, Davis Besse Kentucky 1
Zimmer 4
Big Rock Pt, D.C. Cook, Michigan Palisades, Fermi Minnesota A
Prairie Island (2), Lacrosse Monticello+
Zion, Lacrosse, P'rairie Island (2):
Kewannee/Pt. Beach Illinois 5
LaSalle, Dresden(2), Quad Cities,'
Zion Iowa 3
Quad Cities, Ft. Calhoun, Duane Arnold Arkansas 1
Arkans as' Nebraska 1
Ft. Calhoun Colorado 2
Ft. St. Vrain(2)
San Onofre, Diablo Canyon l
1 Trojan Oregon j
Trojan
- Utility did not participate; prior to issue of GM-17 on Joint Exercise Procedures l
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STATES NOT YET EXERCISED STATE DATE SCHEDULED-FACILITY Connecticut 2/ 6/82 - Conn-Yankee 3/20/82 - Millstone Massachusetts 3/ 3/82 - Pilgrim 3/25/82 - Yankee Rowe New Hampshire 2/18/82 - Seabrook
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Vermont 2/18/82 - Vt.-Yankee Florida 3/30/82 - Crystal River 2/11/82 - St. Lucie 3/15/82 - Turkey Point Indiana
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- Marble Hill Texas 7/ /82 - Comanche Peak 5/ /83 - So. Texas Kansas 11/ /82 - Wolf Creek Missouri 8/ /82 - Calleway Arizona 9/ /82 - Palo Verde e
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EXISTING IlulE PROPOSED fll!LE
- LICENSEE IIEQUlllED TO EXERCISE
- CONTINUE TO REQUIRE LICENSEES fu EXERCISE ANNUALLY ANNUALLY
- FULL-SCALE AND SHAlt.-SCAL.E EXEllCISES
- REDUCE LOCAL CGVERNMENT FULL PARTICIPAIlON REQUIRED 10 INCLUDE STATE AND LOCAL WITil Tile LIEENSEE AND STAIE fil0H ANNilALLY GOVERNMENT PARTICIPATION 10 BIENNIALLY.
s
- filEQUENCY Of SI ATE AND LOCAL PARTICI-
- REDUCE STATE FULL PARTICIPATION fil0H PATION ANNUALLY TO DIENNIAll.Y DUT llEQUIRE PARTIAL STATE PARTICIPATION IN YEARS WilERE N0 FULL PARTICIPA110N.
o AT EACll SITE ONCE EVERY 5 YEARS
- CllANCE FROM S TO 7 YEARS IllE HINIMUM TIME o FOR EACll STAIE AND LOCAL GOVEllNHENT FOR A STATE TO DE A FULL PARTICIPANT IN Wlill!N PLUME EXPOSURE EPZ ONCE EACll AN LXERCISE AT EACll SITE WITillN ITS YEAR BORDERS.
o full EACil STATE WlilllN INGESTION EXPOSullE EPZ ONCE EVERY 3 YEARS
- Pil0VIDES F0F PARTIAL EXERCISES, E.G.,
FULL PARTICIPATION DY LICENSEE AND LOCAL FLDERAL PARI 1CIPATION AT EACil SITE GOVERNMENT AND PARTIAL PARTICIPATION BY EVEllY 5 YEARS Tile STATE.
- INCLUDE PROVISION FOR A TABLE TOP PROTECTIVE ACTION DECISIONHAKING DRILL FOR STATE AGENCIES IN ANY YEAll TilEllE IS NOT PARTIAL OR FULL PARTICIPATION.
FEDERAL PARTICIPATION AT EACil SITE EVERY 7 YEARS H
.