ML20056H411
| ML20056H411 | |
| Person / Time | |
|---|---|
| Issue date: | 05/25/1993 |
| From: | Congel F Office of Nuclear Reactor Regulation |
| To: | Wingo C Federal Emergency Management Agency |
| References | |
| NUDOCS 9309090281 | |
| Download: ML20056H411 (3) | |
Text
O O
%Y 2 5153 Craig S. Wingo Assistant Associate Director Office of Technological Hazards Federal Emergency Management Agency l
500 C Street, S.W.
Washington, D.C.
20472
Dear Mr. Wingo:
. t ~ :d ue liRL Si.o t t comments on IEMA's drott Guidance Memorandum (GM) RG-2, 6
as published in the Federal Reaister on February 8, 1993. We appreciate the opportunity to comment on this FEMA draft guidance for implementing Executive Order (E.0.) 12657 in accordance with FEMA's rules in 44 CFR Part 352.
j If you or members of your staff have any questions regarding our comments, i
l please feel free to contact me or Aby Mohseni of my staff at (301) 504-2925.
Sincerely, Original signed by Frank J. Congel, Director l
Division of Radiation Safety and Safeguards Office of Nuclear Reactor Regulation
Enclosure:
i As stated DISTRIBUTION Central Files LJCunningham NRC & Local PDRs PMcKee PEPB R/F PEPB Staff FCongel g4 u d
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DATE 05/13/93*
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t ENCLOSURE l
NRC STAFF CCMMENTS ON FEMA DRAFT GUIDANCE MEMORANDUM (GM) RG-2, GUIDELINES FOR REGIONAL IMPLEMENTATION OF FEMA'S RULE,44 CFR 352 l
PART III. GUIDELINFS FOR REGIONAL IMPLEMENTATION OF 44 CFR PART 352 l
Section C.
Criteria for the Existence of Decline or Fail Situations Subsection 2.
Criteria for Failure to Adequately Participate Coment: We recomend the first sentence be revised as follows:
l The Regional Director may recomend that a fail i
situation exists if it is determined that one or more of the following three criteria are met n_.g i
consecuence of in cenjuncti:n with the involved State or local governments' lack of comitmeat or capability to make adequate improvement:
Reason:
The revised wording makes it clear that a fail situation i
recomendation is premised upon planning inadequacies or exercise failures which are the result of the lack of comitment of the State or local government, not those which may happen to exist at the same time but are unrelated to governmental participation.
PART IV. SPECIFIC AREAS OF RESPONSIBILITY FOR REGIONAL OFFICES Section A.
Consulting with State and Local Officials on Decline or Fail Situations Comment: The second bullet contains a sentence which we recomend revising as follows:
The HR0 should work closely with the RAC. the licensee. and the NRC Recional Administrator in an attempt to resolve decline or fail situations through the use of 44 CFR 350 or through h e
- pplication Of th: "rcalism :::umption:" cent:in:d utility measures desioned to compensate for any emeroency plannino deficiencies resultino from State l
and/or local nonparticiDation as Drovided in the NRC l
rule, 10 CFR 50.47(c)(1)...
1
[ Recommended additions are identified by bold underlining and recom-mended deletions are identified by strikeout.]
Reason:
The proposed revision is consistent with the provisions of 10 CFR 50.47(c)(I), consistent with draft RG-2,Section IV.E regarding j
coordination with NRC Regional administration, and consistent with
o o
NRC's actions under 44 CFR 352.6(b) to advise FEMA regarding the extent to which the licensee has complied with 10 CFR 50.47(c)(1).
j Early involvement of the RAC is consistent with draft RG-2,Section IV.D. (Providing Technical Assistance) and Section IV.F.
(Coordinating and Consulting with RAC Members).
Section H.
Arranging for a Federal Response in the Licensee Offsite Plan w __..> r, t : We recommend the third sentence to be revised as follows:
When advised to do so by FEMA Headquarters, the HR0 will' coordinate through the RAG Reaional Interaaency i+eerine Committee (RISC):
Reason:
According to the Federal response system developed by FEMA, these two functions belong to the RISC. These Federal personnel are intimately involved in the policy, plan and procedure development for response of Federal resources to support State and local authorities in an emergency. The RAC members are seldom the individuals who plan Federal response in their respective agencies.
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