ML20045D682
| ML20045D682 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/27/1992 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Gordon Peterson Federal Emergency Management Agency |
| Shared Package | |
| ML20044B583 | List: |
| References | |
| FOIA-93-125 NUDOCS 9306290296 | |
| Download: ML20045D682 (1) | |
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UNITED STATES
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'f WASHINGTON, D.C. 20555 October 27, 1992 Mr. Grant C. Peterson Associate Director State and Local Programs and Support-Federal Emergency Management Agency Washington, DC 20472
Dear Grant:
As a result of NRC's inadequate coordination of the Turkey Point restart with FEMA at both the lieadquarters and Field levels, I conducted an assessment of i
where the NRC process failed.
Enclosed for your information is a copy of the assessment which I-sent to the Commission on October 20.
Also enclosed is a followup memorandum I sent to the Commission on October 26.
If you have any questions, please give me a call.
Sincerely,
/
a'es M. Ta r
ecutive D rector for Operations Enciosures:
1.
Memo to Commission dated October 20, 1992 2.
Memo to Commission dated October 26, 1992 9306290296 930505 PDR FOIA
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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WASHINoToN, D.C. 20665 i
October 20, 1992 MEMORANDUM FOR:
The Chairman Commissioner Rogers Commissioner Curtiss Commissioner Remick Commissioner de Planque FROM:
James M. Taylor Executive Director for Operations p
SUBJECT:
TURKEY POINT UNIT 4 - SHUTDOWN BECAUSE OF 0FFSITE EMERGENCY PREPAREDNESS CONCERNS
Background
Hurricane Andrew caused the shutdown of Turkey Point Units 3 and 4 on August 24, 1992.
Following substantial effort on the part of Florida Power and Light (FP&L) to repair storm-related damage, U.iit 4 was ready for restart by late September.
Unit 3 was in a refueling outage. On September 28, 1992, the NRC staff concurred in the licensee's readiness to restart Unit 4.
Subsequently, the plant commenced startup and attained 30% power by October 1, 1992.
On October 1,1992, after several conference calls with and a request from senior NRC management, FP&L senior management agreed to a shutdown of Turkey Point Unit 4.
The basis for the request and subsequent shutdown was a Federal Emergency Management Agency (FEMA) concern regarding the status of offsite emergency preparedness (EP), including verification of offsite emergency planning, verification of the availability of facilities and equipment, and j
analysis of the unique conditions existing in the emergency planning zone (EPZ) in the wake of Hurricane Andrew.
FEMA had not been given sufficient notification by the NRC of the impending Unit 4 startup and therefore had not had the opportunity to perform the necessary verification of offsite emergency preparedness.
Subsequent to the plant shutdown, FEMA dispatched a team to Dade County, Florida to commente the verification activities.
NRC personnel assisted the FEMA team and functioned as team members under the leadership of the FEMA team manager.
Initial analysis of the NRC's management of the offsite emergency preparedness aspects of the Turkey Point Unit 4 restart indicated a number of weaknesses or lapses in coordinating the process. Consequently, to determine root causes and lessons learned, both Region II and the Office of Nuclear Reactor Regulation (NRR) performed critical self-analyses of their respective roles in the restart process.
These reports are enclosed.
In addition, Jim Sniezek and I met with the key NRC headquarters and Region II personnel associated with the Turkey Point restart to explore the root causes fer this breakdown in our restart process related to offsite EP.
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The Commission Discussion Extensive onsite and offsite damage occurred at Turkey Point as a result of Hurricane Andrew.
FP&L and the NRC conducted comprehensive onsite damage assessments and inspections following the storm.
FP&L identified and the NRC concurred in the equipment and other items to be repaired, restored, retested, or otherwise addressed as a prerequisite to plant restart.
These items formed 1
the basis of the restart criteria and inspection plan developed by Region II.
Region 11 formed a task force to monitor the licensee's recovery operations and activities.
During the recovery period, Region II and NRR maintained close and active contact with the licensee.
However, the restart process was flawed in that acknowledgement of the status of offsite emergency preparedness was lacking and sufficient coordination with FEMA had not taken place.
A variety of f actors contributed to a flawed restart process resulting in premature restart concurrence and the subsequent shutdow'n of Unit 4.
Deficiencies included poor internal and external communications and coordination, lack of a formalized restart process with attendant procedures and checklists, a lack of management and staff focus on the effect that unique offsite conditions would have on plant restart, and inadequate training / knowledge of the role of and relationship with FEMA.
Communications / Coordination The chronologies attached to the enclosed Region II and NRR self-assessments demonstrate substantial coordination in the restart process.
Nevertheless, inadequate communications and coordination at several levels were major contributors in the failure to identify the need for an offsite EP assessment.
Limited coordination and inadequate communications between Region II divisions resulted in incomplete participation in the restart process by the technical division with responsibility for EP.
Communications between Region 11 technical divisions and their counterparts in NRR were inadequate and, in part, contributed to NRR's failure to provide FEMA headquarters with current and complete information regarding the schedule and status for startup of Turkey Point. Within NRR, inadequate coordination between Projects and the Division of Radiation Protection and Emergency Preparedness (DREP) also contributed to the failure of the NRC to communicate adequately with FEMA i
headquarters. A more proactive posture on the part of DREP in following the progress of Turkey Point restart and in communicating with FEMA headquarters would also have been beneficial.
Finally, the external communication between Region II and FEMA Region IV was inadequate in that FEMA was not contacted until after plant startup.
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Restart Process While the restart plan used by Region 11 for Unit 4 startup was extensive and included substantial inspection activities, it was developed in an ad hoc manner. Without a defined formalized restart process, restart criteria were developed by Region II that did not include any requirements related to offsite EP.
Consequently, the need to coordinate EP assessment activities with FEMA was never identified.
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The Commission Management / Staff focus l
Staff and management attention following the hurricane was appropriately focused on reactor safety. NRC activities for several weeks after the hurricane were concentrated on assessing storm-related damage, licensee actions to maintain reactor safety, and actions to restore equipment / systems i
necessary for plant restart. The staff did an excellent job in this regard.
However, although aware of the storm effects in the surrounding area, the NRC focus at Turkey Point generally remained "inside the fence." The staff was generally not sensitive to the impact of the storm on offsite EP and consequently did not include appropriate consideration for verification of offsite EP.
Additionally, as restoration at Turkey Point progressed, NRC emphasis on restart activities became more routine. Management and staff attention returned to other high priority issues.
Consequently, as restart approached, senior NRC management missed an opportunity to question the restart criteria and in particular the status of offsite EP. Another contributing factor in this area was a lack of staff recognition of the uniqueness of the situation at Turkey Point and the surrounding area.
This was the first nuclear power plant to suffer such a major natural disaster and the impact of the resultant devastation of the surrounding area was not fully appreciated. As a result, a special approach to match the uniqueness of the situation was not used.
Knowledge / Training In general, the level of staff understanding of the role and responsibilities of FEMA regarding offsite EP as well as the NRC relationship with FEMA appears to be inadequate.
A variety of staff, including managers, expressed a lack of knowledge regarding these issues. While training in these areas has been conducted in the past, either it had limited effectiveness or a broad enough audience was not included. An associated deficiency involves confusing inspection guidance related to EP.
Some inspection procedures imply that it is an inspector's responsibility to assess aspects of offsite EP that are normally within the purview of FEMA.
Conclusion While the post-hurricane onsite activities of the staff were comprehensive and well-coordinated, a significant deficiency in the staff approach to plant restart existed. The combined factors noted above resulted in incomplete restart criteria regarding the need for verification of the acceptability of offsite EP and in inadequate communication and coordination with FEMA.
i The Commission [h07 2 0199?
Actions Corrective actions are necessary to address each of the factors noted above.
Additional training of headquarters and regional staff in the role and responsibilities of FEMA and the relationship of the NRC to FEMA will be conducted.
Existing guidelines for plant restart (NRC Inspection Manual Chapter 0350) will be modified to incorporate lessons learned and address restart plans and criteria for plants shut down following significant events.
Inspection procedures will be reviewed to ensure they properly reflect the separation of NRC and FEMA responsibilities regarding EP.
In addition, although not an immediate factor in the Turkey Point restart issue, the NRC-FEMA Memorandum of Understanding will be reviewed and revised as necessary to ensure the respective roles of the NRC and FEMA are clearly defined for situations similar to this.
Discussions have been held with appropriate-staff and managers involved in the restart to ensure their understanding of the issues and deficiencies. This paper and the Region II and NRR self-assessments will have wide dissemination in the staff to ensure the lessons learned are thoroughly understood.
I will provide the Commission with the details of these corrective actions as they are further developed.
Origina! Signed By:
James M. Taylor James M. Taylor Executive Director for Operations
Enclosures:
As stated i
UNITED STATES p Clouq'o NUCLEAR REGULATORY COMMISSION i
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Octo ber 13, 1992 MEM0PANDUM FOR:
James M. Taylor Executive Director for Operations FROM:
Stewart D. Ebneter Regional Administrator
SUBJECT:
REVIEW OF THE TURKEY POINT RESTART DECISION We reviewed Region II participation in the Turkey Point Unit 4 restart decision. The enclosed report was prepared based on a review of the chronology of activities related to emergency preparedness readiness and discussions with the Region II staff.
The root cause of the premature decision, premature because the Federal Emergency Management Agency (FEMA) was not consulted before the restart, was the omission of a requirement in the restart criteria to obtain FEMA input with regard to the status and continuing acceptability of offsite emergency preparedness. A number of factors that contributed to the omission of the FEMA input were identified. These are poor communication / coordination, mindset with regard to offsite preparedness, perceived low priority of the restart, limited staff knowledge of the FEMA role, and a low sensitivity to the imoortance of offsite preparedness.
We have addressed the specific Turkey Point problem and have reemphasized the importance of the FEMA role.
A more extensive list of corrective actions will 23, 1992.
This will include the easily recogniz-be provided by October able ones of training and strengthening of internal interfaces, plus recommendations for more generic actions.
g Stewart D. Ebneter
Enclosure:
Report of Turkey Point Restart Decision g sV@
REVIEW OF DECISION TO CONCUR IN RESTART OF TURKEY POINT UNIT 4 INTRODUCTION The Region II staff in conjunction with other agency organizations concurred with the restart of the Turkey Point Nuclear Plant Unit 4 on September 28, 1992. The decision was premature in that the Federal Energy Management Agency (FEMA) was not consulted to determine if there were any concerns related to off-site emergency preparedness. Region II internally reviewed the decision and the decision process used. Staff members who were part of the process or who should have been part of the process took part in the review. The review was limited to Region II.
S_UMMARY Region II's internal review of the restart decision revealed that the root cause of the premature decision was the failure to incorporate in the restart criteria any off-site emergency preparedness review.
Factors contributing to this failure, and preventing further review during the restoration for restart were found to be:
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poor communication / coordination with internal and external interfaces a mindset that limited the scope of the restart concerns perceived low priority of Turkey Point restart limited knowledge of Agency external interfaces low sensitivity to the importance of offsite emergency preparedness BACKGROUND Hurricane Andrew, one of the most severe hurricanes ever to strike Florida, caused the shutdown of the Turkey Point Nuclear Plant Units 3 and 4 on August 24, 1992.
Subsequent to the passage of the storm, damage assessments and inspections were conducted by the Florida Power and Light Company (FP&L) and the NRC. FP&L identified the items to be repaired, restored, retested, or addressed as a prerequisite to return to service of the units. These were concurred in by the NRC and formed the basis-for the restart criteria for restart of Unit 4.
Unit 3 was to enter a refueling outage before restart and thus was not part of the decision process.
4 THE PROBLEM The problem was that the NRC concurred in the restart of Turkey Point Unit 4 prior to consulting with FEMA to ascertain if the offsite emergency plan remained adequate to support the FEMA " reasonable assurance" finding (44CFR 350).
ROOT CAUSE The root cause of the failure to consult FEMA was the incomplete restart criteria. The restart criteria did not include the requirement to determine the adequacy of the offsite emergency preparedness.
Exhibit 1 is a simplified diagram of the proper restart decision process. Note that it should have included a FEMA input into the restart criteria.
Exhibit 2 is a simplified diagram of the restart decision process as it occurred.
Note that no FEMA input to the restart criteria occurred. Thus, all subsequent actions--
planning, restoration, inspection, verification and the concurrence in restart--did not include a request for review of the adequacy offsite emergency preparedness. The factors that contributed to this are discussed below. Further, there was sufficient time to revise the restart criteria during the restoration process but the contributing factors also caused the staff to not consult FEMA for input.
Exhibit 3 is a partial chronology of liurricane Andrew restoration which indicates onsite emergency preparedness was reviewed and FP&L made interface contacts with local and state officials with regard to offiste preparedness. Note that Region II had no contact with FEMA IV with regard to Turkey Point Unit 4 restart either formally or informally prior to restart of the unit.
CONTRIBUTING FACTORS The root cause of the premature decision was the incomplete restart criteria.
Several factors were identified that contributed to the omission of the inclusion of a requirement for the review of the adequacy of the offsite emergency preparedness (OEP).
Poor Communication and Coordination Inadequate Region II communications, both internal and external, were a major i
factor in the failure to identify a need for OEP review.
Internal communications has two facets, both of which were inadequate.
Internal to the Region II staff, the Division of Reactor Projects was assigned the lead for restart oversight. Support was to be provided by the technical specialist division in which the emergency preparedness expertise resides, There was limited Division of Radiation Safety and Safeguards, (DRSS).
participation in the briefings, status reviews of Turkey Point activities by The appropriate technical divisions provided staff support to complete DRSS.
inspection and verification activities but had little input to the planning or analysis of restart needs. Communication and coordination between Region II technical divisions and the Office of Nuclear Reactor Regulation (NRR) f technical organization was also inadequate which probably contributed to the failure to provide FEMA headquarters with complete information with regard to the startup date of late September (the NRR technical organization is the i
primary interface with FEMA headquarters).
Region II has a responsibility to assure timely and complete information flows from technical divisions to the counterpart NRR technical division and this communication / coordination was inadequate.
Communication / coordination between the Regional projects office and the NRR projects office was handled well.
External communication, i.e., the Region II to FEMA IV interface, was inadequate. The Region II RAC representative has an established communication channel with FEMA IV, but this interface was not exercised prior to the startup decision.
Further, there should have been a sensitivity to offsite emergency preparedness on the part of the RII managers and specific members of the technical staff and the topic should have been addressed. Once identified, the staff could have contacted the FEMA IV staff for input.
Mindset There appears to have developed a mindset that inhibited the communication with FEMA.
Previous national issues with emergency preparedness have clearly defined the scope of responsibility for the two agencies (NRC and FEMA) and this has led to a "not our job" mentality on the part of some NRC Region II staff members. Thus, there is reluctance to step on " FEMA turf" by some. The mindset is also fostered by emergency drills and exercises in which NRC participates.
Staff participation in these exercises usually terminates when the unsafe condition scenario is brought under control and rarely does the Regional staff interface with FEMA during these exercises and/or drills that go beyond the accident into the restoration phase.
FEMA activities are primarily review of procedures and plans for offsite preparedness.
Region II staff focus is on-site activities, particularly safety of reactor systems which tends to cause NRC technical staff to develop a bias toward the hardware and develop a mindset that the reactor safety 11 the only consideration.
Low Priority Although senior managers kept a high priority on the situation at Turkey Point and a single point of contact was assigned to assure all activities were coordinated, some complacency apparently set in and resulted in a lowering of the priority to Turkey Point activities. This was probably due to the good performance of FP&L during the storm and during the subsequent restoration activities. The physical plant suffered little damage from the hurricane and there were no major obstacles to overcome during the restoration. Thus, staff members pursued other activities, placed lower priority on and less attention to Turkey Point restart planning and reviews.
Inadecuate Staff Trainina During the review of the restart decision more than a few staff members displayed a surprising lack of knowledge of the FEMA role and responsibility for emergency preparedness.
It was clear, either the training that was given over the years has not been effective, not periodically reinforced, or has not been provided to much of the staff.
Inspectors and managers alike commented
that they "did not know what FEMA's role was," or that they had not been exposed to the FEMA interface.
Restoration activities were performed quickly and effectively. Thus, with little knowledge of the importance of offsite emergency preparedness, or responsibility for it, it is easy to see how it could be overlooked as a restart item.
Sensitivity Clearly, there was a lack of staff sensitivity, i.e., low threshold of awareness of the importan'ce of the FEMA role and offsite emergency planning.
This is probably an outgrowth of the inadequate training, infrequent contact with external interfaces and the mindset that the NRC job is on-site reactor systems. A lack of sensitivity leads to a dismissal or denial, of the importance of the offsite functions and, therefore, little or no concern for importance of obtaining diverse inputs in relation to startup activities.
Higher sensitivity would have led to a more pro-active stance on the part of Region 11 with regard to the FEMA interface.
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EXHIBIT 1 i
DAM Gi-RESTORATION FP&L ASSESS O SIRENS O C O M M U N ICATIO N S hEO
--O O
O P HONES oCIRCutTS R' ~ ~
O ETC CERTtFY p'~ CONCUR s
T VERIFY L__
gg RESTART NRC DAMAGE RESTART PtaN
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-- IN SP ECTIO N S - - - -
g!soinb ASSESS t o,,,
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T O
O O --
R O-I A
o REVOKE REASONABLE REVIEWS TO DAMAGE
^SSuR4NCE E Stasti S n
- - + FIN DIN G REASONABLE ASSESS
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NEED TO REVIEW / CONFIRM PROPER DECISION PROCESS (SIMPLIFIED) w e
EXHIBIT 2
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i CERTIFY FPat R E STOR Af lON COMPLETE
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TEN TATIV E on....
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CONCUR
^CTuAL FP&L ^ -*
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- + RESTART DAT E NRC -*
nesses
- nnsasa RESTA R T DAT E 9
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- NRC
--* VE RIF Y NRR INSPECTION BY AND INSPECTION REGION VERIFICATION CON TACTS FEMAIV STATE & LOCAL PLAN
- CONFIRMED BY FP&L
- ORP PROJECT ENGINEER ASMED FP&L PLANT MANAGER
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H PLAN TO FINDING FEMA.
Review NOT-REASONABLE N
(Need To peyjg ASSURANCE Never Communicated Between NRC & FEMA) _
ACTUAL DECISION PROCESS (SIMPLIFIED) a -
EXHIBIT 3 TURKEY POINT RESTART INFORMATION TIME LINE October 13,1992, 9:30 am OBJECTIVE: The following is listing of communications which were applicable to the identification of a planned September 30, 1992, online date at Turkey Point that could have prompted the need for an assessment of Emergency Preparedness.
Plant status is periodically listed to relate planned to actual startup dates.*
DATE ACTIVITY COMMENT 24 AUGUST EDO STAFF NOTE:
ON 24 AUGUST, AT 4:15 AM, REGION II HURRICANE ANDREW ACTIVATED THE INCIDENT RESPONSE CENTER HIT TURKEY POINT (IRC).
UNIT 3 IN MODE 4 AT 3:12 AM, UNIT 4 IN MODE 4 AT 4:05 AM, OFFSITE POWER WAS LOST, AND COMMUNICATIONS WERE LOST AND REGAINED 25 AUGUST ED0 STAFF NOTE RII IRC REMAINS ACTIVATED.
TP UNITS STABLE IN HOT SHUTDOWN WITH NO 0FFSITE POWER. ACCESS ROAD TO SITE BEING CLEARED - EXPECTED TO BE OPEN THIS MORNING.
27 AUGUST ED0 STAFF NOTE TP UNITS IN COLD SHUTDOWN.
EQUIPHENT STATUS DISCUSSED.
REGIONAL AND RESIDENT INSPECTORS ONSITE FOR CONTINUED 24 HOUR COVERAGE.
28 AUGUST REGION II ITEM 0F RII ACTIVATED IRC ON 24 AUG AT 4:15 INTEREST AND AM. CONTAINED THREE PAGE DETAILED EDO STAFF NOTE DESCRIPTION OF EFFECTS OF HURRICANE ANDREW ONSITE: ESF EQUIP FUNCTIONED PROPERLY, COMMUNICATIONS LOST AND REGAINED, EQUIP DAMAGE, SENIOR RESIDENT INSPECTOR ONSITE, 24 HOUR INSPECTION COVERAGE BEGAN, ETC.
RII IRC REMAINS ACTIVATED.
31 AUGUST FPL DRAFT OF FAXED TO REGION II AS A DRAFT WITH RECONSTRUCTION PROJECTED RETURN TO SERVICE OF 30 RESTART SCHEDULE SEPTEMBER I SEPTEMBER RSLO DISCUSSION PRIOR TO LEAVING DISASTER FIELD OFFICE WITH THE FEMA FC0 (DFO), MIAMI, THE REGION 11 STATE LIAISON OFFICER (RSLO) DISCUSSED TP WITH FEMA FCO,ET.AL. FEMA DID NOT DISCUSS OFFSITE EMERGENCY PREPAREDNESS
- NOTE:
This is net a complete chronological listing of all actions or information relative to Turkey Point recovery from Hurricane Andrew
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Exhibit 3 (Continued) l 2
DATE ACTIVITY COMMENT 2 SEPTEMBER EDO STAFF HOTE RII ASSURED FEMA THAT THERE WERE NO RADI0 ACTIVE RELEASES AT TP AND THAL RII INSPECTORS HAVE BEEN ONSITE CONTINUOUSLY DURING AND SUBSEQUENT TO THE STORM MONITORING ACTIVITIES 2 SEPTEMBER NRC INPUT TO FEMA FPL HAS NO PROJECTED DATE FOR UNIT 4
't SITUATION REPORT RESTART i
3 SEPTEMBER PHO-II-92-055C STATED - LICENSEE PROJECTING RESTART 7:00 AM OF UNIT 4 IN APPROXIMATELY 30 DAYS 4 SEPTEMBER REGION II ITEM OF MEDIA INTEREST. ON I SEPT, RII INTEREST AND ASSURED FEMA THERE WERE NO RADI0 ACTIVE r
EDO STAFF NOTE RELEASES. ON 2 SEPT, RII PROVIDED l
STATEMENT TO BE USED FOR INQUIRIES REGARDING TP/ HURRICANE CHRONOLOGY OF EVENTS AND RESULTS OF RADI0 ACTIVE i
SURVEYS.
ON 4 SEPT, BOTH UNITS IN COLD SHUTDOWN, TWO SOURCES OF OFFSITE POWER RESTORED, AND DAMAGE TO FOSSIL i
UNIT EXHAUST STACK.
j 5 SEPTEMBER TELECON BETWEEN PROVIDED J0E HIMES (AE00), NRC C0NTACT SINKULE AND HIMES W/ FEMA, THAT FPL PLANS UNIT 4 RESTART IN APPROXIMATELY 30 DAYS - FOR INPUT l
INTO FEMA SITUATION REPORT i
FEMA SITUATION STATES: FPL EXPECTS TO RESTART UNIT 4 REPORT #19 IN APPR0X 30 DAYS"
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7 SEPTEMBER RSLO MET WITH JOHN DISCUSSED TP STATUS TO INCLUDE HEARD, RAC CHAIRMAN RESTART. NEITHER RESTART DATE, NOR-l ET. AL. TO DISCUSS OFFSITE EMTRGENCY PREPAREDNESS WERE FRP AND FRERP DISCUSSED 10 SEPTEMBER NRC (NRR AND RII MEETING WAS TO DISCUSS FOSSIL UNIT ATTENDED) MEETING STACK INTEGRITY. HAND 0UT INCLUDED
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WITH FPL ONSITE.
UNIT 4 RESTART SCHEDULE PROJECTING ON-EDO STAFF NOTE LINE DATE OF 30 SEPTEMBER i
11 SEPTEMBER REGION II ITEM OF ON 10 SEPT, RA AND NRR/AD MET WITH FPL INTEREST AT TP TO DISCUSS OVERALL DAMAGE ASSESSMENT AND RECOVERY ACTIONS j
17 SEPTEMBER FAX TO NRR PROJECTS FAXED THE SCHEDULE OF NRC INITIATIVES 8:00 AM FOR UNIT 4 STARTUP WHICH IDENTIFIED 30 SEPTEMBER AS THE STARTUP DATE i
- NOTE:
This is not a complete chronological listing of all actions or information relative to Turkey Point recovery from Hurricane Andrew
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Exhibit 3 (Continued) i 3
DATE ACTIVITY COMMENT 17 SEPTEMBER 10 SEPT MEETING RELEASED TO PUBLIC (PDR) THE MTG
SUMMARY
ISSUED
SUMMARY
OF 10 SEP MTG W/ FPL CONTAINING COPY OF RESTART-SCHEDULE WHICH PROJECTED ON-LINE 30 SEPT 18 SEPTEMBER REGION II ITEM OF BOTH UNITS IN MODE 5.
PLANNED RESTART INTEREST OF UNIT 4 ON 30 SEPTEMBER.
SITE STATUS WAS GIVEN.
22 SEPTEMBER NRC HEETING WITH DISCUSSED RECONSTRUCTION AND UNIT 4 FPL ONSITE RESTART PLAN PROJECTING ON-LINE DATE OF 30 SEPTEMBER-24 SEPTEMBER GUTAM BAGCHI MEMO ASSESSMENT OF TP UNIT 2 STACK TO J. RICHARDSON INTEGRITY - ALSO STATED UNIT 4 ON-LINE DATE OF 30 SEPTEMBER 25 SEPTEMBER RII MEETING WITH RA REGION 11 MEETING WITH ALL TECHNICAL DIVISIONS WAS CONDUCTED TO BRIEF THE RA ON NRC EFFORTS TO VERIFY READINESS OF TP UNIT 4 TO RESTART 25 SEPTEMBER REYES HTG W/LAINAS NO UNIT 4 RESTART CONCERNS WERE r
AND PARTLOW IN HQ IDENTIFIED 25 SEPTEMBER TELECON: R. SCHIN, W. PEARCE VERIFIED ACCURACY OF PNO-2:00 PM RII TO W. PEARCE, 11-92-062 AND STATED THAT FPL HAD BEEN TP PLANT MANAGER IN FREQUENT CONTACT WITH STATE AND LOCAL COUNTIES AND THERE WERE NO PROBLEMS IN THAT AREA 25 SEPTEMBER PNO-II-92-062 MEDIA INTEREST IN TP STATUS AFTER HURRICANE ANDREW - STATES ON-LINE DATE OF 30 SEPTEMBER 25 SEPTEMBER REGION II ITEM OF MEDIA INTEREST.
UNIT 4 SCHEDULED TO INTEREST BE ONLINE BY 30 SEPTEMBER.
TP EXITED UNUSUAL EVENT AT 12:20 PM EDT N 22 SEPTEMBER WHEN METEOR 0 LOGICAL'T0WER REPAIRS COMPLETE AND SAFEGUARDS.
SYSTEMS RE-ESTABLISHED.
EQUIPMENT STATUS WAS DESCRIBED 27 SEPTEMBER BEGAN 24-HOUR RESIDENT INSPECTOR 24-HOUR COVERAGE INSPECTION COVERAGE BEGAN IN 8 HOUR SHIFTS COMMENCING.ON ONSITE DAY SHIFT
- NOTE:
This is not a complete chronological listing of all actions or information relative to Turkey Point recovery from Hurricane Andrew
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Exhibit 3 (Continued)
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4 DATE ACTIVITY COMMENT 28 SEPTEMBER TIA ISSUED TO HQ TIA STATED UNDERSTANDING THAT NRR WAS FROM MERSCH0FF TO SATISFIED WITH THE EVALUATION OF FIRE LAINAS PROTECTION AND UNIT 2 STACK INTEGRITY 28 SEPTEMBER CONFERENCE CALL DISCUSSED FPL PREPARATIONS FOR RESTART WITH NRR/RII/FPL OF UNIT 4 - NO CONCERNS WERE 3:30 PM IDENTIFIED TO PREVENT START UP 29 SEPTEMBER UNIT 4 IN MODE 2 REACTOR CRITICAL AT I:33 AM 1:18 AM 29 SEPTEMBER RII RAC COMMITTEE JOHN HEARD, FEMA RAC CHAIRMAN WHICH 1:00 PM, MBR,R. TROJAN 0WSKI, OVERSEES OFFSITE PREPAREDNESS, 2:20 PM, TELECON WITH FEMA, INFORMED RII THAT STATE AND COUNTY CAN 3:50 PM REGION IV IMPLEMENT EMERGENCY PLAN.
29 SEPTEMBER PN0-II-92-063 MEDIA INTEREST IN TP STATUS AFTER 9:00 AM HURRICANE ANDREW - STATED NRC REVIEWED AND CONCURRED IN UNIT 4 RESTART 29 SEPTEMBER BRIEF 0F SENATOR BRIEFED DAN BERX0WITZ ON NRC ACTIONS GRAHAM STAFFER TO VERIFY READINESS FOR UNIT 4 RESTART 4:30 PM 29 SEPTEMBER UNIT 4 WAS RETURNED AUTO AFW ACTUATION'AND TWO MISSED 4:25 PM TO MODE 3 SURVEILLANCES FOUND (NON-RELATED)
LICENSEE EN 24335 30 SEPTEMBER EDO STAFF NOTE ON 29 SEPT, RII BRIEFED SEN. GRAHAM STAFFER ON NRC INSPECTION ACTIVITIES AT TP.
EXTENSIVE NEWS HEDIA INTEREST 30 SEPTEMBER MORNING REPORT UNIT 4 5 HUT DOWN DUE TO MISSING TWO 2-92-0109 SURVEILLANCES (VENTING THE ECCS AND RUNNING STDBY FW SYSTEM IN RECIRC) AND ACTUATION OF AFW WHEN CONDENSATE POLISHER CAUSED LOSS OF MAIN FW ON LOW SUCTION PRESS 30 SEPTEMBER UNIT 4 STARTUP MODE 2 AT 2:00 AM, REACTOR CRITICAL AT RECOMMENCED 2:17 AM, I OCTOBER UNIT 4 STARTUP MODE I AT 2:10 AM, GENERATOR PLACED CONTINUED ON-LINE AT 3:52 AM,' INCREASED POWER TO 30% FOR CHEMISTRY HOLD
- NOTE:
This is not a complete chronological listing of all actions or information relative to Turkey Point recovery from Hurricane Andrew
- - -. ~.. -. -.
Exhibit 3 -(Continued) 5 DATE ACTIVITY COMMENT 1 OCTOBER RSLO ADVISES FEMA, DADE COUNTY DEPUTY DIRECTOR REITERATED 8:55 AM STATE.AND DADE TO RSLO THAT COUNTY PLAN CAN BE l
COUNTY OF NRC PRESS IMPLEMENTED WITHOUT ANY CHANGES CONFERENCE AT TP DN 2 OCTOBER 1 OCTOBER FEMA (HEARD, FEMA ADVISES RII THAT FEMA MUST 9:05 AM WOODARD AND KOHL)
PERFORM ASSESSMENT OF REASONABLE CONTACTS RII DRA ASSURANCE AND RSLO 1 OCTOBER NRC REQUESTS FPL TO NRC/ FEMA /FPL DISCUSS EVACUATION SHUT DOWN UNIT 4 CAPABILITY FEMA INSPECTION REQUIRED (FROM 30% POWER)
LASTING APPROX 2 WEEKS I OCTOBER UNIT 4 SHUT DOWN HODE 2 AT 8:24 PM 7:15 PM BEGAN MODE 3 AT 8:36 PM 1 OCTOBER SECURED 24 HOUR SECURED ON PEAK SHIFT FOLLOWING 11:00 PM INSPECTION COVERAGE OBSERVING EffiRANCE INTO MODE 3 AND COOL DOWN INITIATED 2 OCTOBER REGION II ITEM OF ON 29 SEPT, RII BRIEFED SEN. GRAHAM INTEREST AND STAFFER ON RII INSPECTION ACTIVITIES EDO STAFF NOTE AT TP. ON 2 OCT, NRC PRESS CONFERENCE AT TP SITE TO DISCUSS DELAY OF UNIT 4 OPERATION FOR APPROX 2 WEEKS TO ASSESS OFFSITE EMERGENCY PREPAREDNESS.
RII DIRECTOR DRSS AND STATE LIAISON OFFICER AT DISASTER FIELD OFFICE IN MIAMI OBSERVING FEMA'S ASSESSMENT-ACTIVITIES i
PERIODIC DISCUSSIONS AT THE DRP 8:15 MORNING MEETING (NRR PARTICIPATES)
PROVIDED THE STATUS OF TURKEY. POINT UNIT 4 PREPARATIONS AND PROGRESS TOWARD MEETING THE SEPTEMBER 30 PLANNED ONLINE DATE.
NUMEROUS DISCUSSIONS WERE CONDUCTED WITH NRR PROJECTS AND REGION 11 PROJECTS TO VERIFY THAT PLANNED INSPECTIONS AND ASSESSMENTS WOULD BE COMPLETED AND THAT STARTUP CONCERNS WOULD BE IDENTIFIED AND RESOLVED IN SUPPORT OF THE PLANNED UNIT 4 ONLINE DATE OF SEPTEMBER 30.
i
- NOTE:
This is not a complete chronological listing of all actions or information relative to Turkey Point recovery from Hurricane Andrew
e,## *%
0 UNITED STATES o
E i
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20655
%,*****/
October 15, 1992 MEMORANDUM FOR:
James M. Taylor Executive Director for Operations FROM:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation
SUBJECT:
EVALUATION OF STAFF PARTICIPATION IN TURKEY POINT REC 0VERY AND RESTART FOLLOWING HURRICANE ANDREW At your request, we have done a brief critical review of our activities related to the Turkey Point recovery and restart decision, especially as they pertain to offsite emergency preparedness.
The enclosed report discusses the root causes of the premature restart concurrence, the major contributing factors, and the lessons learned to preclude similar problems in the future.
A chronology of NRR activities and actions is provided as an attachment to the report.
Action items, consistent with implementing the lessons learned, will be developed.
~
Thomas E. Murley, Dir ctor Office of Nuclear Reactor Regulation
Enclosure:
As stated 0
@gs*4 q
ENCLOSURE EVALUATION OF STAFF PARTICIPATION IN TURKEY POINT RECOVERY AND RESTART FOLLOWING HURRICANE ANDREW Introduction The purpose of this report is to document and evaluate NRR's actions related to the Turkey Point recovery and restart decision, as they pertain to offsite emergency preparedness, to identify the root causes of NRR's premature restart concurrence and the contributing factors, and the lessons learned from the experience.
On August 24, 1992, Turkey Point Units 3 and 4 sustained extensive site damage as a result of Hurricane Andrew.
South Florida was declared a disaster area by the President and a Federal Response Plan seeking assistance from various federal agencies, including FEMA and NRC, was implemented.
As a result of the hurricane, there was a complete loss of offsite power, communications and access by road, and damage to the fire protection and security systems.
In addition, the offsite alert notification system was lost.
Immediately after the hurricane, the licensee began its damage assessment and' recovery operations with the objective of restoring Unit 4 to operable status as quickly as possible and then initiating the previously scheduled Unit 3 refueling outage activities.
The licensee's immediate damage assessment indicated that restoration of Unit 4 could take several months.
During the recovery period the NRC staff, both Region II and NRR, maintained an extensive and active interface with the licensee.
In addition to a Regional presence at the site, there were several meetings at the site, and staff reviews of licensee actions and supporting documentation.
Notwithstanding the licensee's immediate estimate, by early September the licensee announced plans to restart Unit 4 by the end of September.
On September 28, 1992, the NRC staff reviewed and concurred in the licensee's readiness for restart.
The licensee restarted the unit on that date.
During power ascension on October 2, 1992, at the NRC's request, the licensee brought Unit 4 to cold shutdown because it became evident that FEMA had not completed its assessment and confirmation of the current adequacy of offsite emergency preparedness capabilities.
i
. Problem The problem was that a FEMA " reappraisal" or "recertification" was not conducted in a timely manner due to inadequate coordi-nation between Projects and DREP (now DRSS) to. consult with FEMA in a timely manner to support the restart.
There was a lack of sensitivity within NRR to the need for FEMA input on a restart decision involving offsite matters.
Contributing Factors Region II formed a task force to monitor all the licensee's recovery operations and activities.
A Technical Interface Agreement (TIA) was prepared coordinating Region II and NRR activity.
NRR reviewed the acceptability of the interim fire protection configuration, Unit 1 stack demolition and Unit 2's stack damage condition for restart.
While there was active coordinatic' between Projects and the NRR divisions involved-in the TIA, there was insufficient coordination between Projects and DRSS, with respect to the. responsibility for the FEMA interface.
The root cause of this problem is that there were no coherent restart criteria with respect to the emergency preparedness which would have identified all the necessary elements and activities for restart, including assigned responsibilities.
Lessons Learned 1.
Develop Restart Criteria Any restart plan following a shutdown due to a significant event should begin with a detailed checklist of required licensee and staff actions as well as actions by other entities.
The checklist should specifically include consideration of offsite emergency preparedness issues.
The restart plan with its checklist should be reviewed and concurred in by all cognizant organizational elements.
The use of confirmatory action letters (CAL) and TIAs which identify required licensee and staff actions should be required.
This should ensure that all necessary aspects of restart receive adequate consideration.
2.
Strengthen Interface Between Region and NRR,, and Within the NRR Organizations j
Staff understanding of the interfaces and scope of responsibilities of the Regions and the Headquarters organizations should be strengthened, particularly during situations involving a plant restart following a shutdown due to a significant event.
The Projects organization should coordinate i
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4 with every technical division director to assure appropriate involvement of that division.
This would ensure that each organization is adequately represented in making the restart decision.
As evidenced by the chronology of events, documentation existed which identified the restart activities in progress, including the restart schcdule.
However, there should be sufficient proactive coordination to assure that such documentation receives adequate consideration.
4 9
P
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ATTACHMENT TURKEY POINT UNIT 3/4 CHRONOLOGY OF NRR INTERACTIONS DATE ITEM 1.
8/26/92 Events Assessment Branch presentation.
Sequence of events following Hurricane Andrew and its impact on Turkey Point Units 3/4.
2.
8/26/92 Director's Highlight.
Licensee's damage assessment in progress.
Licensee believes that it could take several months to recover.
3 8/27/92 Region II issues PNO-II-92-055A.
South Florida declared a disaster area.
Federal Response Plan calls for assistance from various agencies, including FEMA, DOE, EPA, NRC, etc.
4.
8/31/92 Memorandum from E. Jordan (AEOD) to T. Murley, "
Commission Notification and Charter for the Review of Hurricane Andrew's Impact on Turkey Point."
Goal is to describe damage and compile experience gained from the hurricane impact through a joint NRC/ Industry team.
5.
8/31/92
.L. Raghavan (PM) returns a call from Ms. Elaine Chan of FEMA Headquarters.
Provided general detail of storm damage to plant.
6.
8/31/92 Region II forwards to NRR " Turkey Point Recovery Organizational Charter (Draft)."
Project Director of PDII-2 is proposed to be the NRR liaison to the Task Force.
7.
8/31/92 Region II forwards to NRR licensee's proposed interim fire protection configuration.
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8.
9/1/92 C. Wingo (FEMA) asked R. Erickson (PEPB) to send copies of NRC's daily event summary reports on Turkey Point issued by the Operations Center. _The first one sent was dated 8/31/92.
The last one was dated 9/22/92.
9.
9/1/92 Region II forwards to NRR licensee's schedule for restart of Unit 4.
Unit 4 to return to service on i
September 30, 1992.
10.
9/2/92 Licensee forwards a copy of 10 CFR 50.59 evaluation for demolition of Unit 1 stack using controlled explosives.
i
11.
9/2/92 Telephone conversation between NRR, Region II and the licensee.
Discussed plant status, Interim fire protection configuration and licensee's proposal to demolish Unit 1 Stack by controlled explosive charge.
NRC discusses need for seismic instrument recorders, ground impact of fall of the stack, stack collapse direction, safety precautions.
NRR reviews the 50.59 evaluation and finds it acceptable.
12.
9/4/92 Region II, with NRR concurrence, verbally approves suspension of continuous fire watch for a few hours during the demolition of Unit 1 stack.
13.
9/4/92 Unit 1 stack demolished by controlled explosives.
14.
9/4/92 The licensee requests a " Tempora'ry Waiver of Compliance" to suspend continuous fire watch for a few hours during demolition of Unit 1 stack.
15.
9/7/92 Licensee's special report.
High range noble gas monitor has not been returned to service within 7-days as required. Alternate method for monitoring consistent with TS implemented.
16.
9/8/92 Memorandum from A. Chaffee, Chief, Events Assessment Branch, to C.
E. Rossi, Director, Division of Operational Events Assessment, with copies to senior NRC management.
Notes of 8/26 presentation (Item 1 above), summary of sequence of events following Hurricane Andrew.
17.
9/8/92 Region II, with NRR concurrence, documents the Temporary Waiver to suspend fire watch during demolition of Unit i stack.
18.
9/8/92 Daily Highlight.
" Turkey Point Hurricane Damage".
Informs that Unit 1 stack has been demolished by controlled explosive charges (see item 13).
19.
9/9/92 FPL letter to NRC details Turkey Point actions concerning plant security during and after the storm 20.
9/9/92 FPL letter to NRC provides Turkey Point Units 3/4 Emergency Plan Assessment Report as of September 7,
1992.
Discusses status of EP elements.
21.
9/9/92 Director's Highlight on general status of plant.
22.
9/10/92 NRR and Region II meeting with the licensee at site. Discussed licensee's damage assessment of Hurricane Andrew and recovery plans, schedule and status including emergency preparedness.
Unit 4 restart scheduled for 9/30/92.
23.
9/11/92 Internal Memorandum from L. Shao (RES) to E.
S.
Beckjord, Director, Office of: Nuclear Regulatory Research, with copies to T. Murley, W. Russell, et. al.
General discussion of impact of hurricane on Turkey Point.
Review damage to plant, background information relating to IPEEE and PRA for Turkey Point.
Included a list of vulnerable structures and possible questions on wind damage to plant.
Describes possible future actions, i.e., review hazard curves used in the PRA and IPEEE reviews.
24.
9/14/92 E-Mail from G. Bagchi, Structural and Geoscience Branch, to M. Sinkule (Region II).
Indicates need-to assess damage to fossil unit stacks.
25.
9/16/92 Director's Highlight identifies 9/30/92 date for Unit 4 restart.
26.
9/16/92 Telephone conference between S. Varga, G.
- Lainas, L. Raghavan, and F.Congel relating to Risk Application Branch review of Turkey Point IPE following the hurricane.
27.
9/17/92 Meeting Summary issued by Region II for September 10, 1992 meeting (see item 22).
Provides detailed damage assessment, recovery status and schedule.
28.
9/17/92 Memorandum from L. Raghavan, thru S.
Varga, to T.
Murley, F. Miraglia, J. Partlow and W.
- Russell, with copies to Region II.
Discusses current status, recovery and restart plan, other activities, observations and identifies action items. Inc3uded as enclosures licensee's damage assessment results, overview of U-3/4 recovery plan, and excerpts from the licensee's IPE submittal.
29.
9/21/92 H. Berkow and L. Raghavan met with W. Beckner (Risk Applications Branch) relating to Turkey Point IPE following the hurricane.
l
30.
9/22/92 NRR meeting with.the licensee at site.
Discussion i
on Interim fire protection, Unit 2 stack structural evaluation and restart plan.
NRR found the' interim fire protection configuration and Unit 2 stack in the present condition acceptable for restart.
Indicated the need for licensee's reevaluation of its IPE following the hurricane..
The licensee confirmed its plan to revisit its IPE-analysis.
The licensee would provide schedule for this effort.
31.
9/23/92 Director's highlight reconfirms 9/30/92 as the plant restart date. Indicates that Region II will issue a TIA.
32.
9/24/92 L. Raghavan (PM) and S. Long (Risk Applications Branch) discuss with E. Weinkam, Licensing Manager, FPL plant data relevant ~to IPE.
33.
9/24/92 Memorandum from G.
Bagchi, Chief, Structural and Geoscience Branch, to J. Richardson, Director, Division of Engineering Technology, with copies to W. Russell, Region II, et. al.
Summary of 9/22/92 meeting (see item 30) relating to assessment of structural integrity of Unit 2 stack in the existing condition.. Concludes that the Unit'2 stack in the existing condition is acceptable for restart.and provides recommendation for long term.
34.
9/24/92 L. Raghavan returns a call from Ms. Lorion (Floridian for Safe Energy).
Provides details of interim. fire protection configuration.
35.
9/25/92 NRC Letter from L. Raghavan to Ms. Lorion.
Forwards a copy of TS relating to fire protection and a copy.of 10 CFR 50.59.
36.
9/28/92 Telephone conference between NRR, Region II'and the licensee to discuss readiness for. restart.
Discussed. completion of various restart action items including the interim fire protection configuration, licensee's management oversight on site, EP routes and offsite-EP facilities.
Licensee's Corporate Nuclear-Review Board has reviewed the restart operations.
37.
9/28/92 Region II issues TIA.
Identifies nine significant-NRC actions required for restart.
n y
38.
9/29/92 H. Berkow announced Turkey Point Unit 4 restart in the weekly DRP/ DST Branch Chief's meeting. R.
Erickson (PEPB) asked about offsite EP readiness.
Berkov stated RII had addressed EP issues.
39.
9/29/92 D. Barss (PEPB) phoned W. Rankin, RII EP Section Chief, about offsite EP readiness for Turkey Point restart.
He received positive report on sirens, communications, met tower, and evacuation routes, and was. told FEMA Region IV expressed no concerns.
He also mentioned that RII staff was to discuss restart with Senator Graham's staff this day.
40.
9/29/92 R. Erickson phoned C. Wingo (FEMA Headquarters) about the restart and faxed him the latest PN (PNO-II-92-063). Wingo was to contact his staff person, D. Kohl, in the Miami Disaster Field Office, and have him check with' State and local authorities on offsite EP readiness.
Wingo asked for names of contact persons in FP&L and NRC.
41.
9/30/92 R. Trojanowski, RII State Liaison Officer, phoned R. Erickson and reported on his 9/29 contact with J. Heard of FEMA Region IV about offsite EP for Turkey Point.
Erickson shared notes of this call by E-Mail with interested HQ staff.
42.
9/30/92 R. Erickson express-mailed to Craig Wingrc (FEMA) all the-documents we could find dealing with the restart, including PNs and the Region's letter summarizing its restart meeting with FP&L.
43.
10/1/92 Daily Highligt,
" Turkey Point, Units 3/4."
Provides genc
. plant status.
44.
10/6/92 Draft memor_. Mum from S.
Long to W. Beckner,
" Estimate of Conditional Core Damage Probability for the Impact of Hurricane Andrew on Turkey Point."
45.
10/13/92 Meeting summary for 9/22/92 meeting issued (see item 30). NRR documents its evaluation and acceptability for restart the licensee's Interim fire protection configuration and Unit 2 stack damage condition.
Also includes; recommendation for inservice surveillances of the Unit 2 stack pending its modification.
October 26, 1992 MEMORANDUM FOR: The Chairman Commissioner Rogers Commissioner Curtiss Commissioner Remick Commissioner de Planque FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
SUPPLEMENT TO EDO MEMORANDUM OF OCTOBER 20, 1992 ON THE SUBJECT OF TURKEY POINT UNIT 4 SHUTDOWN BECAUSE OF EMERGENCY PREPAREDNESS CONCERNS The purpose of this memorandum is to forward for your information the current Memorandum of Understanding (MOU) between NRC and FEMA dated for the NRC April 3,1985 and for FEMA April 9,1985, as a supplement to my memorandum of October 20, 1992 on the subject of Turkey Point.
As noted in the enclosed MOU (page 6), an NRC/ FEMA Steering Committee was established "to be a focal point for coordination of emergency planning, preparedness and response activities between the two agencies." This Steering Committee, through the respective agency co-chairs, would have been a logical place to coordinate the emergency preparedness issues associated with the restart of Turkey Point Unit 4 on September 28, 1992.
As I indicated in my October 20 memorandum to the Commission, although not an immediate factor in the Turkey Point restart issue, the NRC-FEMA Memorandum of Understanding will be reviewed and revised as necessary to ensure the respective roles of the NRC and FEMA are clearly defined for situations similar to this.
~ 0thic!cto-M:y Jam = 0 ?ces James M. Taylor Executive Director for Operations i
Enclosure:
As stated cc: SECY OGC W<f W
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}EMDRANDUM OF um:.iw41DDG BtWEEN FRC MiD FDM RE!.ATDG '!O RADIOIIGICAL DdIFGDCl PININRG AND PREPAREEHESS
}M'.
c I.
1%CK@CWD AND PJRKSE Eis Menorardi.ra of Un3erstarding (MOU) establishes a framevxk of ccopera-tion 1:eten the Federal Emergency Managerent Agency (FD%) and the U.S.
Nuclear Regulatory Ccanission (tac) in radiological energency response planning ratters, so that their rutual efforts will be directed toward nere effective plans and related preparedness measures at.and in the vicinity of nuclear rifactors and fuel. cycle facilities which are subject to 10 cm Part 50, Appendix E, and certain other fuel cycle and raterials licensees Wich have potential for significant accidental offsite radice-2e nerorandum is responsive to the President's decision Icgical releases.
of recenter 7,1979, that FD% will take the lead in offsite planning and response, his request that NRC assist FD% in carrying out this role, and the lac's continuing statutory responsibility for the radiological health.
and safety of the public.
14, 1980, the two agencies entered into a 'Menorandum of On January Understanding Between N7C and FD% to Acccnplish a Pres pt Inprovement in Radio 1cgical Drergency Preparedness" that was responsive to the A revised and updated w andum President's recenber 7,1979, statenent.
cf understarding f.ecare ef fective Ibvember 1,1980. B is MOU is a further revision to reflect the evolving relationship between imC and FDM and the experience gained in carrying out the provisions of the January ard ibverter 1930 MOU's.
Bis MOU supersedes these two earlier versions of the M7).
Be general principles, agreed to in the previous MW's and reaffimed in this MW, are as fo11cus:
FD% ccordinates all Federal planning for the offsite irpact of radiological energencies and takes the lead for assessing offsite radiolcgical erergency response plans
- an5 preparedness, rakes firdirgs an3 deteminations as to the adeqtiicy'an5 capability of.
l d ccumnicates those findings ard detemina-
. irplerenting offsite p ans, arse 130 reviews those FD% firdings and determinations
~
tions to the NRC.
in conjunction with 1a0 onsite firdings for the purpose of making determini-
%ese overall findings tions on the overall state of energency preparedness.
ard 6eteminations are used by lac to rake radiological health and safety 6ecisions in the issuance of licenses ard the continued operation of licensed plants to include taking enforcerent actions such as istices of violations, civil penalties, orders, or shutd:wn of operatire reactors.
his delineation of responsibilities avoids duplicative efforts by the N?C staff in offsite preparedness natters.
- Assess:ents of offsite plans nay be based on state and localTpvernment plans subnitted to FD% under its rule (44 CFR 350), and as notedlin 44 CFR 350.3(f), ray also be based on plans currently available to mR irr furnished to FD% through the imC/FD% Steerirg Ccmnittee.
~ -j i
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1,'
. 22, 1980, deals with NRC/FD% cooperation A separate }CU dated October and responsibilities in response to an actual or potential radiological Cperations Fesponse Procedures have been developed that energency.
These documents inplenent the prcuisions of the Incident Response M3J.
are intended to be consistent with the Federal Radioicgical Emergency Response Plan Wich describes the relationships, roles, ard responsi-bilities of Federal agencies' for responding to accidents involving peace-tire nuclear energencies.
II. MUDRITIES AND RESPCNSIBILITIES FD% - Executive Order 12148 charges the Director, FD%, with the respansi-bility to "... establish Federal policies for, and ccordinate, all civil defense a-d civil crergency plannire, rnanagement, nitigation, and assistance functions of Executive agencies" (Section 2-101) and "... represent the President in working with State an$ local governnents and the private sector to stinulate vigorous participation in civil energency preparedness, rdtigation, response, and recovery prograns."
(Section 2-104.)
On Decerter 7,1979, the President, in response to the recormendations of the Keneny Camission on the Accident at Three Mile Islan5, directed that FD% assum lead responsibility for all offsite nuclear energency planning and response.
Specifically, the FD% responsibilities with respect to radiological e.ergency preparedness as they relate to IE are:
To take the lead in offsite energency planning ard to review an$
1.
essess offsite energency plans ard preparedness for adequacy.
To nahe firdings an5 determinations ah to Wether offsite emergency 2.
plans are adequate and can be inplenented (e,g., adequacy ard raintenance of precedures, training, resourms, staffing levels ard qualifications, ard equipment adequacy). 7btwithstanSing the
~
procedures which are set forth in 44 CFR 350 for requesting an5 rea6ing a FD% administrative approval of State ard local plans, firdings, ard determinations on the current status of energency planning and preparedness around particular sites, referred to as interim firdirgs, will be provided by FD% for use as needed.in
~
the mc licensing process. Such firdings will be provided by FD%
The on mutually agreed to schedules or on specific NRC request.
regaest ard firdirns will normally be by written ccrmunications 1:etween the co-chairs of the NRC/FD% Steering Ocmnittee. - An interim firding provided under this arrangenent will be an extension of FD%'s procedures for review an$ approval of' offsiteradiological enerpency plans and preparedness set forth in 44 CFR.350. gt will be tesed on the review of currently available plans and, if*appro-priate, joint exercise results related to a specific nuclear pcuer plant site.
An interim firdire based only on the review of currently available offsite plans will include an assessnent as to Whether these plans are adequate when measured against the stardards an$ criteria of EREG-0654/FD%-REP-1, ard, perding a denonstration through an
~
s 1.
- exercise, whether there is reasonable assurance that the plans The finding will indicate one of the following can be implemented.
(1) Plans are adequate and there is reasonable assurance conditions:
that they can be implemented with only limited or no corrections needed; (2) plans are adequate, but before a determination can be made as to whether they can be implemented, corrections must be made to the plans or supporting measures must be demonstrated (e.g.,
adequacy and maintenance of procedures, training, resources, staffing levels and qualifications, and equipment adequacy); or (3) plans are inadequate and cannot be implemented until they are revised to correct
- deficiencies noted in the Federal review.
If in FEMA's view the plans that are available are not completed or are not ready for review, FEKA will provide NRC with a status report delineating milestones for preparation of the plan by the offsite authorities as well as FEMA's actions to assist in timely developreent a.d review of the plans.
An interin finding on preparedness will be based on review of currently available plans and joint exercise results and will include en assess-rant as to (1) whether offsite energency plans are adequate as measured a;ainst the standards and criteria of HUREG-0554/ FEMA-REP-1, and (2) whether the exercise (s) demonstrated that there is reasonable assurance tnat the plans can be implenented.
An interim finding on preparedness will indicate one of the following (1) There is reasonable assurance that the plans are conditions:
tre;uate end can be implenented as demonstrated in an exercise; (2)
Inere are ceficiencies that may adversely affect pubife health and safety that must be corrected in order to provide reasonable assurance t at the plans can be implemented; or,(3) FEMA is undecided and will provide a schedule of actions leading to a decision.
To assure responsibility, as a supplement to State, local, and utility 3.
ef f orts, for radiological emergency preparedness training of State and local of ficials.
To develop and issue an updated series of interagency assignments 4
which delineate respective agency capabilities and responsibilities and define procedures for coordination and direction for energency
[ Current assignments are in 44 CFR 351, planning and response.
March 11, 1982.
(47 FR 10758)).
HRC - The Atomic Energy Act of 1954, as amended, requires that the NRC grant licenses only if the health and safety of the public is adequately While the Atomic Energy Act does not specifically fequire protected.
emergency plans and related preparedness nessures, the NRC The NRC rules (10 CFR 50.33, 50.34, 50.47, 50.54, and Appendix process.
E to 10 CFR Part 50) include requirements for the licensee's emergency plans.
l o
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' e,. 3.,
- L :--
Sgecifically, the tac responsibilities for radiological energency preparedness are:
1.
7b assess licensee energency plans for adequacy. ' Ibis review will include organizations with wbcn licensees have written aposants to,
. provide onsite support services under energency conditions.
2.
2 verify that licensee energency plans are adequately ir:plenented (e.g., adegaacy ard raintenance of procedures, training, rescurces, staffing levels ard qualifications, ard equipaent).
3.
% review the FD% firdings and determinations as to whether offsite plans are adequate and can be Irplerented.
4.
To rake radiolcgical health and safety decisions with regard to the cverall state of emergency preparedness (i.e., integration of ener-gency preparedness onsite as 6etermined by the lac an$ offsite as determined by PD% and reviewed by tac) such as assurance for continued o,reration, for issuance of cperating licenses, or for takire enforcerent actions such as notices of violations, civil penalties, orders, or shutd:wn of cperating reactors.
III. ACIAS OF CCOPD%TICH A.
h c Licensine Reviews FD% will prcuide support to the imC for licensing reviews related to reactors, fuel facilities, ard raterials licensees with regard to the assess ent of the adequacy of offsite radiolcgical energency response n ' t=
.f preptrefness.
Tnis vill include tirely sutraittal of an evaluation suitable for inclusion in tac safety evaluation reports.
Substentially prior to the tire that a FDR evaluatico is required with regard to fuel f acility or raterials license review, imC will identify those fuel ard raterials licensees with potential for significant accidental j
offsite radiolcgical releases and transmit a request for review to NA as the energency plans are ccepleted.
FDZ routine support will include providirg assessnents, firdings and deterr.inations (interim and final) on offsite plans and preparedness related to reactor license reviews. 7b support its firdirns and determinations, FD% will rake expert witnesses available beforfthe-Ccrnission, the imC Advisory Ccr.nittee on Reactor Safeguards, imC hearing boards ard administrative law ja5 es, for any court actions, ard during any 9
related discovery proceedirgs. -
l 1
FD% will appear in imC licensing proceedirgs as part of the'pNsentation
~
of the 10C staff.
FDR counsel will' rcrually present FD% witnesses l
and be pern,itted, at the discretion of the imC licensirs board, tc6 cross-I examine the witnesses of parties, other than the imC witnesses, on matters involving TD% firdirgs ard determinations, policies, or cperations; however, FD% will not be asked to testify on status reports.. FD% is not a party to imC proceedings and, therefore, is not subject.4o formal discovery require:ents placed upon parties to lac proceedings. Osnsistent with j
e
1
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s
~
available resources, however, MA will respord infomally to discovery requests by parties.
Specific assignment of professional responsibilities between 1a0 and MA counsel will be primrily the responsibility.of the.
attorneys assigned to a particular case.
In situations where questions of professional responsibility cannot be resolved by the attorneys assigned, resolution of any differences will te nade by the General Ccunsel of MA ard the Executive Iegal Director of the imC or their designees. ImC will request the presiding Board to place FDM on the service list for all If tigation in which it is expected to participate.
Nothing in this docunent shall be construed in any way to diminish imC's responsibility for protecting the radiological health and safety of the public.
B.
D A Review of Offsite Plans and Preparedness IE will assist in the develepcent ard review of offsite plans ard prepar-einess thrcogh its re: ership on the Regional Assistance Ccnmittees (PAC).
TA will chair the Regional Assistance Omnittees.
Cbn:;istent with IZ's statutory responsibility, lac will recognize MA as the interface with State ard Iccal govern.ents for interpreting offsite radiological e ergen y planning ard preparedness criteria as they affect t}x>se govern-rents ard for reporting to thcoe governnents the results of any evaluation of their radiolcgical emergency plans ard preparedness.
Khere q.:estions arise concerning the interpretation of the criteria, such gaestiens will continue to be referred to &A Headquarters, and when appro-priate, to the IE/WA Steering Cconittee to assure uniform interpretatien.
C.
Pre eration for ard Evaluation of Joint Exercises
&A aM !a: vill cocperate in determining exercise requirenents for licensees, State a-d Iccal governnents. ney will also jointly observe ard evaluate exerci ses. lE ard MA will institute precedures.to enhance the review of the etjectives ard scenarics for joint exercises. mis review is to assure
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that both the onsite considerations of 1m0 ard the offsite considerations of &A are adequately addressed and integrated in a enner that will prcvide for a tes.nically scord exercise upon which an assessnent of preparedness capabilities can be based.
@e IRO/MA precedures will pn: wide for the availability of exercise objectives and scenaries sufficiently in advance of schedaled exercises to allev enough tine for adequate review'by 130 ard TA ard correction of any deficiencies by the licensee. W e failure of a licensee to 6evelop a scenario that adequately addresses both onsite ard offsite considerations ray result in imC taking enforcerent actions.
c9 he MA reports will be a part of an interim f.frding on energ,ency pre -
s paredness; or will be the result of an exercis,e corducted pursuant,.to MA's review ard apprcual procedures urder 44 CrR 350. Exercise (valua-tions will identify one of the following conditions:
(1) mere is reasonable assurance that the plans are adequate ard can be inplenented as denonstrated in the exercise; (2) there are Beficiencies that rey adversely inpact public health ard safety that rnost be corrected by the affecte) State aid local goverrcents in order to provide reasonable assurance that the plan can be inple ented; or (3) MA is undecided ard will prcnide a schedule of actions leading to a decision. Within 30 days of the exercise, a draft exercise
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report will be sent to the State, with a copy to the Regional Assistance Ccuraittee, requesting otzments an$ a schedule of wcuctive actions, as Where there are deficiencies of appropriate, frcn the State in 30 days.
the types noted in 2 above, and khen there is a potential for a remedial-cxercise, FD% Headquarters will prcrptly discuss these with NRC Head-Within 90 days of the exercise, the TDM report vill be quarters.
Within 15 days of receipt of the FDM.
forwarded to the imC Headquarters.
re; ort, lac will notify PD% in writing of action te. ken with the licensee relative to MA initiatives with State an5 local governments to correct deficiencies identified in the exercise.
D.
Dmrgency Planning an5 Preparedness QJidance IUC has lead responsib}11ty for the develegnent of emergency plaming FD% has lead res;onsibility and preparedness guidance for licensees.
for the developcent of radiolcgical emergency planning ard preparedness lac and FD% recognize the need guidance for State and 1ccal agencies.
for an integrated, coordinated approach to radiolcgical emergency planning NRC and prepareiness by NRC licensees and State and local goverrcents.
and MA vill etch, therefore, prcai& op;ortunity for the other agency to review aM " rent on such guidancs (including interpretations of agreed joint guidance) prior to adcption as formal agency guidance.
E.
Succort for Dtcu ent Management System IL}'A and 23C will each prtn16e the other with continued access to those autcratic data processing support systems which contain relevant urgency preparedness data.
At 1K, this incluSes D:crent Manage:ent System support to the extent it 6:es n:t affect duplicatico or records retention. At PEFA, this t?.t:
inclu$es technical sup; ort to the Radiolcgical Emergency Preparedness nis agreenent is not intended to include Manage ent Infomation System.
the autcrated inferration retrieval support for the national level energency response facilities.
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F.
Chooin 120 Research and Develegrent Fisoa.s ongoing 10C and MA research and develescent gepars that are related to State and local radiolcgical energency planning ard preperedness will tac and pa% will cach prcuide vnvitanity for the be ocordinated.
other agency to review end cerment on relevant research and develepr:ent programs prior to inplerenting them.
G.
Public Infornation an$ Educaticn Prcqrams MA will take the lead in develeping public inforratien anS education lac will assist FD% by reviewing for accuracy educational raterials concerning radiation and its hazards and information regarding prcgrams.
f c;pwriate actions to be taken by the general public in the event o an,
>f.,.f accident involving radioactive r.aterials.
IV. 1GC/FD% STEERDG CDNITITE
':he imC/FD% Steering Cccmittee on Energency Preparedadss will continue to be the focal point for ocordination of energency planning, prepared-D e Steering ress, ard response activities between the two egencies.
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's, Cemittee will consist of an equal nunber of ambers to represent each agency with cne vote per agency. Hben the Steering Cemnittee cannot agree on the resolution of an issue, the issue will be referred to SUC and FD'A ranagenent. Se imC rnenbers will have lead responsibility for licensee planning ard preparedness and the FD4A r.enbers will have lead responsibility for offsite planning ard preparedness. 'Jhe Steering -
Ccmittee will assure ccordination of plans and preparedness evaluation activities ard revise, as necessary, acceptance criteria for licensee, State, ard local radiolcgical energency plannirg ard preparedness.
lac an$ FD% will then ocnsider ard adopt criteria, as awwpciate, in their respective jurisdictions.
(See Attachnent 1.)
V.
WE:nn ARFucEMans A.
Se rcrral point of centact for inplenentation of the points in this MOU will be the ?GC/FD'A Steering Ccmittee.
j B.
Se Steering Ccm.ittee will establish the day-to-day procedures for "*"
assuring that the arrargerents of this Pm are carried out.
VI. Y3D?Ra.M OT U::DERSTANDnn A.
Eis MCO shall be effective as of date of signature ard shall continue in effect unless tenninated by either party upon 30 days notice in writing.
B.
A erri ents or redifications to this EU reay be rade upon written agree. ent by both parties.
Agy:wed for the U.S. Ibelear Approved for the Federal Aegalatory Ccrnission Dmrgenef Managenent Agency O C.J 4
4/9/E5 April 3,1985 f,,.
v Nillia:t J. Dircks (Date) el W. Speck (Date)
Executive Director for As late Director Operations State an$ Iocal Fi@ 6 ard Support v.
Attachrent:
FD%/lGC Steerirg Ccr:nittee
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ip.jt+.y Purpose
- t. e. w Assure coordination of efforts to mintain and frprene emergency 'plannirq ard preparedness for nuclear powr reactors as described in the IUC and FDiA rules and the lac /TE"A MJU's on Radiological Emer9ency Platnirg ard Preparedness and Incident Response.
Ccordirate consistent criteria for licensee, State and local e:nergency plans ard preparedness.
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Me:rbership 7he IGO and FD'A consignees of this HOU will designate respective ccM: hairs.,, u for the Steering Cemittee. The designated co-chairs will, in turn, appoint. g.m._,;
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their respective rae-bers to the Ccmtittee.
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Charges to the raerbership of the imC/FD'A Steering Ctzmittee my be h.l4if Q '..
moe by the co-chairs representing the agency whose se=ber is being~ Q 4-charged.
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coentine Prtcedures The steering Ccmittee vill rnaintain a record of each reetirg to 'irclu6e Identification of issues dise'issed ard ecnelusions reached. 16 neeting vill be held without the attendance ard participation of at least the -
co-chairs or two assigned r: embers of each agency.
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E5en ite-s involvirs responsibilities of other ERC gr TEMA offices are
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