ML20127M958

Responds to Questions Raised in 750709 Memo Re Emergency Planning

ML20127M958
Person / Time
Site:	Monticello
Issue date:	07/18/1975
From:	Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Gilinsky NRC COMMISSION (OCM)
Shared Package
ML20127M961	List: ML20127M958 ML20127M976
References
NUDOCS 9211300521
Download: ML20127M958 (6)

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f-Commissioner Gilinsky gg "eMJ MONTICKLLO, MINNESOTA, RADIOLOGICA1, EMERCENCT Resp 0NSE EXERCISE i

By way of answering your enemorandum of July 9th on this subject, some background information may be of interest to you.

The radiological emergency response exercise conducted jointly between the Northern States Power Company's nuclear power plant at Monticello, and Minnesota and local goverrunent organisations, is one of several that have been conducted from time-to-time in various parts of the count ry. Uenally, those exercises are initiated by the involved utility, the State and local governsents or by both the utility and State and local governments.

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NRC's Regional Inspection and Enforcassent Offices require that an emergency preparedness exercise, requiring implementation of the utility's emergency plan, be conducted by the utility prior to olisining j

an operating ifconse. As a part of this exercise, the interface indi-cating the capability for essergency response support on the part of the t

States and local governments la checked by 1&E inspectors. However, the I&E inspectors do not inspect State and local government emergency response capabilities since they have no legal authority to do so.

NRC Regulations (10 CFR 50, Appendix E) merely require that a supportive interface between the utility and the State and local governments exists.

Excerpts from the applicable Regulations concerning the supportive ~ inter-f ace between the utility and State and local soventments with which the utility must comply, are. quoted below I

Excerpts from 1,0 CFR 50 - 3pgendix E, Titlet Emergency Plana _for production and Utilisation Facilities - Content of_ Emergency Pla_n_s "1V.A.

h organization for coping with radLation amarrencies, in which specific authorities, responsiteilities, and

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duties are defined and assigned, and the tru: Sf notification, in the event of an energency. rf j

. h, (1) Persons assigned to the licensee's emergency

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/r organisation, and (2) appropriate State, and I

e yederal agencies with responalbilities'for coping l

with emnergencies:

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Means for determining the magnituJe of the release of radiosctive materials, including criteria for determining the need for notification and participation of local and State agencies and the Atomic Energy Constission l

and other Federal agenci 2, and criteria for determining when protective measures should be considered within and outside the site boundary to protect health and safety 4

and prevent damage to property D.

Procedures for notifying, and agreements reached with, local, State, and Federal of ficials and aPencino for the early warning of the public and for public evacuation or 4

other protective measures should such warning, evacuation, or other protective measuren become necessary or desirable, t

including identification of the principal officials, by title and agencias; 11.

Provisions for training of employees of the licensee who are assigned specific authority and responsibility in the i

4 event of an emergency and of other persons whose assistance may be needed in the event of a radiation emergency i

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Provisions for testing, by periodic drille, of radiation j

amargency plans to assure that employees of the licensee i

are familiar with their specific duties, and provisions for participation in the drills by other persons whose assistance may be nesdad in the event of a radiation emergency."

The Regulations stop short of requiring that a State or local goverruuant prepara a Radiological Emergency Response Plan in support of the facility.

With respect to drills and exercises, the Regulations merely levy upon the licenses the requirement for providing an opportunity for partici-pation in the drille by "other persons whose assistance may be needed i

in the avant of an emergency." ne offsite portions of energency response exercises, such as the exercise conducted by Minnesota and its local governments, are usually not directly evaluated by NRC's Office of -

i Inspection and Enforcement.

The "cajolative" Emergency Preparedness Guidance and Training Program that NRC operates for the benefit of the States and local governments is outlined in the recent Information Paper _ to the Consnimaton, No. gECT 75-344 of July 3,1975. During the past year as a part of this program, the Office of International and State Programs (ISP) han sent an emergency preparedness reprenantative to attend a few State and local

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governcent radiological energency response exercises including the hkinticello, Minnesota exercise. Our role in exercises and the role l

of other Federal agency representatives has always been limited strictly to that of an " observer".

As a result of " observing" the Monticello, Minnesota exercise, the ISP observer and attending Regions 1 observers from other Faderal agencies, did generate some comments which we intend to forward to the State of I

Minnesota. A copy of this letter is attached.

The annvers to your specific questions are as follows:

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Q. 1.

What changes in NRC emergency planning procedurce or organization are dictated by this experience?

A. 1.

First, MRC emergency renponse (plana 6 procedures) and the NRC anergoney response organization were not tested by this exercise.

Therefore, in thin sense, no chanres in our response organisa-tion seems to be in order as a result of this exercise. This was a State exercise involving utility participation along with State and local governrent participation. The exercise revealed certain internal weaknesses within the State and local govern-ment emergency response organizations problems with consnunica-tions, evacuation control, and the general management of the local government Emergency Operating Center by Civil Defense officials were paramount.

Second, our ongoing efforts with the States, i.e. a radiological emergency response planning training program started in March of this year and the Federal Interagency Field Assistance P mgra.

started in December of 1974, to assist States in improving their Radiological Emergency Response Plana and other content-plated activities, are outlined in the aforamentioned Infoetmation Report for the Cocnission. More time is needed to assess the value and impact of these relatively new programs.

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Q. 2.

How should we proceed in filling gaps in multiagency assignments in emergency taska?

I A. 2.

First, assuming that the question refers to "asaltingency assignments" within State and local government organizations, this is largely a problem for State and local governments to work out in their planning efforts. We believe that our guidance document " Guide and Checklist for Development and Evaluation l

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of State and Local Government Radiological rmergency Response Plans in Support of Yixed Nuclear Facilities" (WASH-1293) i published in December 1974 and made available to the States, I

adequately outlinas how a State and local government can avoid "gsps" in its emergency response planning and while I

tasking its variois agencies to accomplish certain things in the event of an emergency.

Second, we should recoCnire here, that the general emergency response posture of many State and local governments appears to un to be weak not only for radiological emergencies involv-ing fixed nuclear f acilities, but for other man-made and natural disasters in general. Nature.11y thesa long standing, inherent weaknesses become evident when the State or local government is forced into an exercise or drill situation involving a fixed nuclear f acility. Repeated exercises cannot i

help but improve the emergency response posture of the States and local governments.

Lastly, if the question refers to gaps in multiagency assign-ments within the Federal Establishment, the new proposed " Notice of Interagency Ramponsibilities, Radiological Incident Energency

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Response Planning -- Fixed Facilities and Transportation" soon to be published by the Federal Freparedness Ap.ency, General Services Administration (FPA/GSA), should be an improvement in coordinating Federal guidance in this area and providing train-ing for State and local governments. The NRC (Commission) con-f curred in this proposed new notice early in July. Additionally, FPA/CSA is developing a Federal Response Plan for Peacetime Nuclear Emergencies (FRPPNE) which should further define and improve the overal1 Federal response capability in radiological amergancies.

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Q. 3.

What feasible measures could be taken to strengthen centralized

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direction of amargency procedurest A. 3.

Assuming that this question refers to the Stato and local i

governments, here again this is a State and local government 6

f responsibility and problem. Our guidanes (WASH-1293) appears adequate in this area and is quite specific concerning this matter.

There are numerous agencies with "an axe to grind" in the emergency response business within a State or local government, each of which is politically motivated to obtain adequate funding and support for its programs. There is nothing, short y

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objectionable Federal intervention or possibly the withholding or revocation of operating licenset., that will hasten the process that a State and local government must go through to ascertain its own weaknesses through the mechantons of weakness revealing drills and emeralses.

A continuation of our "eajolative" guidance in this area esens the best course for the time being, allowing the States to i

ascertain and correct their own weaknesses. The aforementioned j

TRPPNE should siso help to improve the centralised direction of t

emergency planning and operations at the Federal level.

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i Q. 4 What provisions for regular emergency enereises are being madet i

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A. 4.

Nuclear f acilities are required to conduct " periodic" drills of their emergency plans, usually on an annual basis. NRC Regulations

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provide that provisions shall be made for participation in the l

drills by other persons whose. assistance may be needed in the t

i event of an emergency. This has baan interpreted to include State and local government participation.

However, NRC has no direct authority to sospel a State or local

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government to participate in a drill or enereise. But, most States and local governments are becoming involved in drills '

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and euereises with the utilities. Guidanee for State and local

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government drills and exercises in support of fined naalear I

facilities is contained in " WASH-1293". Annual drills and ensreises are reconsnanded.

(Parallela NRC requirements for periodic drills and emereises.)

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We expect to pase on to'all States, the experiences and lessons learned by each of them in conducting.their drills and ensreises. 'There are a -

variety of ways in which this:might be done. One way might be via at j

"NRC Emergency Preparedness Noveletter"..Another way would be via the

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1 States existing civil. Defense organisations and "Regtestal Training.

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One option open to the NRC comeerning improving State and =1ocal govern 4 l

ment emergency response plaamina and operations is.te seek legislation-

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giving NRC the legal authority to force the States and-loosi goverammata i

to develop and-igrove their plans and operations. If adopted, this option will impact on the lisensing process, i.e. 11eenses could be-j I

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withheld if States and local governments did not develop adequate supportive emergency plans. '!his option also appears to be one tentatively being considered by the General Accounting Office as I

they prepare their final draf t report on the subject of NRC's Dnergency Preparedness Program with the States. We expect to receive the draft report for formal coment sometime in late August of this year and the Cocnission vill be advised of CAO's findings.

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(s' gero La v. toukk Lee V Comeick Executive Director for Operations cci Chairman Anders Corrnissioner Kennedy Corniscioner Mason Cominnioner Rowden bcct LVGossick,EDO WJDircks,AEDO TRehm 4

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