ML20137Y024
| ML20137Y024 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 02/18/1986 |
| From: | Hintz D WISCONSIN PUBLIC SERVICE CORP. |
| To: | Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20137Y004 | List: |
| References | |
| CON-NRC-86-18, RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8603120068 | |
| Download: ML20137Y024 (15) | |
Text
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. NRC-86-18 WISCONSIN PUBLIC SERVICE CORPORATION PRIORITY RN;tI %
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g.a FILE h February 18, 1986 Mr. M. P. Phillips U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Phillips:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Emergency Preparedness - Potential Conflicts Between NRC and FEMA Guidelines This letter is written to express our concern for the written contents of the FEMA Guidance Memorandum PR-1, "Folicy on NUREG 0654/ FEMA-REP-1 and 44 CFR 350 Periodic Requirements." The most disturbing point about guidance memorandum PR-1 is the apparent conflicts with 10 CFR 50, Appendix E, section F.3(3) and 44 CFR 350.9(c)(4), without any indication that the appropriate legislative procedures were followed to revise these regulations.
For example, on the topic of exercises which test the capability of States within ingestion exposure pathway to fully exercise their emergency plans, Guidance Memorandum PR-1 (Page 2) reads as follows:
Attendant Criteria Implicit in evaluatio" criterion, N.l.b., is the requirement for each State which has a nuclear power plant within its borders to fully exercise its plans and preparedness related to ingestion exposure pathway measures at least once every six years in conjunction with a plume exposure pathway exercise for some site. This requirement is reflected in the 35 exercise objectivd and is presented in 44 CFR 350.9(c)(4). Each State with ingestion exposure pathway respon-sibilities for two or more sites located within its borders will fully participate at the other sites once every six years. A State which 600 North Adams
- P.O. Box 19002
- Green Bay, WI 54307-9002 .
8603120068 860228 ((g Q 1 1986 f PDR ADOCK 05000305 !
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. .Mr. M. P. Phillips ;
February 18, 1986 Page 2 has ingestion related responsibilities for a site (s) located within its borders and which is also within the 50-mile ingestion exposure pathway of a site (s) located in a bordering State (s), shall partially participate in all of the ingestion related exercises for those bor-dering State site (s). For those States that do not have a power plant located in its borders, but are located within the 50-mile Emergency >
Planning Zone of a bordering State's power plant, they should fully ,
participate in a least one exercise over a six-year period and par-tially participate in all others. These ingestion-related require-ments represent ievision of provisions contained in both i NUREG-0654/ FEMA-REP-1 and 44 CFR 350.9 (c)(4). {
Guidance Memorandum PR-1 states that a six-year cycle is acceptable instead of 5 year cycle as written in 10 CFR 50 and 44 CFR 350. The last sentence states :
that this guidance constitutes a revision to not only NUREG-0654/ FEMA-REP-1 but also 44 CFR 350.9(c)(4). There is no reference to the status of the legal pro- ,
cess initiated to change 44 CFR 350.9(c)(4) and 10 CFR 50 nor any indication '
that the NRC agreed to a revision of NUREG 0654/FFMA-REP-1.
Another area of concern lies in the area of a change to the definition of time frame to meet the after hours exercise guideline of NUREG 0654/ FEMA-REP-1. The guidance memorandum changes the wording in NUREG-0654 from, "Each organization should make provisions to start an exercise between 6:00 p.m. and midnight and another between midnight and 6:00 a.m.," to "Each organization should make pro-visions to start an exercise between 6:00 7.m. and 4:00 a.m." FEMA seems to have taken the philosophy of changing guidelines and giving these guidelines significant weight without apparent coordination or mutual agreement of the NRC 4 nor comment from the general public. '
As you will recall at the January 16-17, 1986 meeting sponsored by FEMA in Chicago, FEMA warned states that repeal of their 44 CFR 350 approvals would be possible if they did not meet the guidance in PR-1. If this should happen the utility is automatically involved. To emphasize our precarious position I would like to quote from a NRC letter to Wisconsin Electric Power Company dated May 16, 1985. The cover letter signed by Mr. C. J. Paperiello, which forwarded the FEMA evaluation of the 1984 exercise at the Point Beach Nuclear Plant, reads as follows: '
"We fully recognize that the recommendations tc be implemented may involve actions by other parties and political institutions which are not under your direct control. Nonetheless, we would expect the subject of offsite preparedness for the area around the Point Beach and Kewaunee Nuclear Power Plants to be addressed by you as well as others."
In summary we are very concerned over the apparent lack of coordination between the national levels of the NRC and FEMA on emergency preparedness guidelines. '
It is our strong belief that NUREG-0654/ FEMA-REP-1 should be reviewed as I necessary to incorporate current philosophy and that this philosophy be incor- i porated into regulations in a timely manner.
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.- .Mr. M. P. Phillips ,
Fabruary 18, 1986 Page 3 Sincerely,
//
D. C. Hintz Manager - Nuclear Power DRS/jks cc - Mr. J. G. Keppler, US NRC - Region III Mr. Robert Nelson, US NRC Mr. William Snell, US NRC Mr. R. S. Cullen, PSCW Mr. George Lear, US NRC i
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Emergency Management Agency
@ Federal Rel ion V 300 South Wacker,24th Floor, Chicago,IL 60606 (312) 353-1500 January 28, 1986 MEMORANDUM FO,: R Assistant Associate Director Office of Natural and Technological Bazards ATTENTION: Robert Wilkerson FROM:
ank Finch, Chief '
Natural a M Technological rds Division
SUBJECT:
REP Training Conference - Followup Issues I would like to thank you for arranging the atte.ndance of Don Kirwan and Marshall Sanders at our January 16-17 REP Training Conference. Don's presentation was quite interesting and informative and several of the attendees noted af terward that they thcaght the information would be use-ful during the next update of their public information brochures. Follow-ing the session, we were able to schedule one-third of our sites for a technical assistance visit.
I would especially thank Marshall for his contribution to the conference.
Being a FEMA BQ policy person, he was continuously "under fire" from the conference participants. I believe that the input from Marshall and the opportunity for direct contact by State and utility planners with FEMA HQ was the most significant positive aspect of the conference.
As 1 am sure Marshall has informed you, there were several issues identified during the conference that require a policy level decision by FEMA HQ. I have attempted to identify these issues in a series of questions and comments which I have enclosed. I have made a commitment to the exercise participants l to followup on these issues and provide them with FEMA HQ response to the j questions. Tc this end, I would appreciate your review of the issues raised and a response to the specific questions. I will ensure that the information l you provide is appropriately distributed within Region V.
In the interim, I am going to provide a response to the questions raised in ,
the November 27 and 29,1985 letters from the State of Wisconsin. This l' response will be based in part on the information provided to me by Marshall during the conference. I will coordinate this response with Marshall. ,
If you wish to discuss further the conference or the 1 ' w e raised, please feel free to contact Wally Weaver of my staff. I look forward to your response to these questions.
Enclosure .
!i!
cct Marshall Sanders
\
IEEP Training Conference Issues January 16-17, 1986
%fs
- 1. Bring State organizations more directly into the review process.
could be acconplished by distributing draft doctanents to the States thru the stegions and increasing review time to 45 - 65 days.
- 2. Were needs to be a more " visible interface" between FDR and NRC as to the coordination which occurs prior to FDR issuance of guidance doctaients. We perception of States and utilities is that FDR is initiating and inplementing activity unilaterally.
- 3. Continuing this idea, some of the guidance issued by FDR is in apparent NRC conflict with regulation (e.g. Gi PR-1 vs NUREG-0654 vs 19-CFR-59).
HQ needs to issue a formal concurrence when FDR guidance is at odds with NRC regulation. (he problem is that FD% tends to " enforce" guidance while NRC " dismisses" an issue by saying " Don't worry about it
. . . it's only guidance.)
- 4. Of the seven areas included in the letter of certification called for in 91 PR-1, only two certifications are Fpecifically required by NUREG-
- 654. We States feel that the reporting regairerrents of the
% e States acknowledge certification letter creats a burden for then.
that the requirements are being met and would be willing to provide a certification statement without the doctanentation.
- 5. We States and utilities would like the " clock Wey to start" feel that FDR isin holding 1983 for the acconplishment of the 35 objectives.
them to requirements they were unaware of at the time if we " start the clock" in 1989 or 1981. Will exenptions (blanket and/or case-by-case) be possible? (%is may be more of a philosophical problern rather than an operational one. FDR V review has indicated that most of the 35 objectives have been met throughout the years although the means for accouplishing then has " evolved" over the same period. W e biggest area remaining is ingestion which is discussed below.)
- 6. Can the States and locals, as appropriate, " transfer" credit for an objective frcun one site to another when the objective is generic in nature? Ris is donte to scme extent when State exercise weaknesses from a full participation exercise are corrected at the next full participation exercise which is usually for a different NPP site.
- 7. Can exercises initiated between 4 A.M. and 6 A.M. be grandfathered in as (Note:
qualifying for an off-hours exercise as defined in G1 PR-17 NIC still his is an area where NRC and FD% use different standards.
holds the utility to "6 P.M. to 12 A.M." and "12 A.M. to 6 A.M.".)
i J 8. %e Statas take exception to the need to condoct unannounced exercises because:
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- "real life" response represents unannounced exercising since sobilization, notification and activation of facilities are the key ;
issues being demonstrated. i 1
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- local resources would be readily available for "real life" response but nust be preplanned for exercises. The cost and volunteer status of many emergency workers nake unannounced exercises inpractical.
There are several related issues. What will FDR's reaction be if a State refuses to conduct an unannounced exercise? Nhat will NRC's reaction to FD%'s reaction be? (Does HR 3938 apply?)
- 9. Exercising in different seasons raises similar issues.
- weather cannot be controlled therefore different seasons may not produce the desired result.
- State and locals oamonstrate the ability to handle " seasonal variations" on a day-towley basis throughout the year.
- many of the activities which are sensitive to " seasonal variations" are tabletop sinulation anyway.
h related questions in 98 above apply here too.
- 10. Are the requirements associated with ANS to be handled on a calendar year basis or on the anniversary date? Based on 01 PR-1, we feel that they are on a calendar year basis.
- 11. Training -
- short notice for RERO course (NV) causes loss of allocation in October or November for same States. h allocatiori from Headquarters nest be out sooner or no courses early in the FY.
- the curricultan of same NET courses is expanded to illl the time available. Perhaps courses should be condensed.
- likewise attendees are recruited to fill the course and are sometimes inappropriate to the content.
- a refresher / advanced RERO course should be developed perhaps keying on Recovery / Reentry and Ingestion issues.
- specific conments about the radiological series courses will be provided by the States - direct contact with Joe I4Fleur of NET was encouraged. (Region V will forward all conrents received.)
- 12. The States (and utilities) would like an apportuity to review a draf t of G1 IN-1 before it is finalised.
- 13. The key issue with respect to ingestion pathway exercises is the magnitude of the effort required. Also many of the criteria (e.g.
sanpling, analysis, dose projection, PAR's, some emm.inications) have direct transferability from inhalation pathway exercises. The level of effort must be defined.
- 14. The States and utill'ties would like a copy of the af ter action report for the Beaver Valley tabletop exercise which is scheduled for '
publication in mid-March. (Region v will ensure distribution if '
provided with a copy sutable for reproduction.)
Emergency Management Agency
@ Federal Region V 300 South Wacker,24th Floor, Chicago,IL 60606 (312) 353-1500 February 5, 1986 Mr. David Speerschneider Director, Bureau of Plans and Preparedness Division of Bnergency Goverrwnent P.O. Box 7865 Madison, Wisconsin 53707
Dear Mr. Speerschneider:
his is in response to your letters of Novernber 27 and 29,1985 wherein you asked several cpestions concerning m PR-1 and m IN-1 (draft). Please note that this letter reflects the information as presented during our recent REP Training Conference in Chicago. A letter to FDR H0 which addresses the issues identified by State and utility representatives at the conference has been prepared and was forwarded to you under separate cover. If the information in this letter is modified as a result of FDR HQ response to the issues letter, I will innediately notify you.
How can Novenber 3,1980, be used to begin the six-year empliance period for meeting all exercise objectives when these objectives were not clearly Tdentified or used until Novenber 19837
%e six-year cycle begins with the first joint exercise conducted af ter the effective date (11/3/80) of the NRC rule,19 CFR 50. We starting date is linked to the NIC rule because this is the initial origin of the requirement for conducting periodic, joint exercises. W e date of the publication of the 35 exercise objectives was August 5, 1983. his is also the effective date for their use. Wese objectives sinply clarify and express in functional terms the demonstrable requirements contained in NUREG-9654/FDR-REP-1 which was pub 11shed in November 1980. FD% Region V is currently reviewing the exercises conducted to date to determine which of the 35 objectives have yet to be successfully dmonstrated for each site.
his information will be provided to you in the very near future. At that time we can nutually assess the inpact of the various starting dates.
When will final guidance be ecmpleted for ingestion pathway planning? How can the six-year cartpliance period for ingestion planning and exercising begin in 1980 when draf t guidance for ingestion plans were not published until April 5, 19857 I
t Because of major She final guidance should be conpleted by July 1986.
technical revisions to the initial draft document, FEMA HQ will consider forwarding a new draft to the Regions and States for review and comment.
States will be held accountable for only those requirements where Fed guidance has been provided.
pathway measures is not provided to states in sufficient time for them to develop and iglement, only the general' evaluation criteria contained in NUREG-9654/FIMh-REP-1 would be used by FEMA to evaluate their exercise Three docunents whis contain " guidance" concerning the performance. evaluation of ingestion pathway exercise objectives1hese were included in the followup conference materials ment to you under separate cover.
materials should be useful for the development of ingestion pathway exercise scenarios.
Will an off-hour exercise have to be wrducted with each plant during the six-year period?
Yes, an off-hour exercise will have to be conducted with each plant during the six-year period. State and local goversnents should have in-place policies and procedures that address the issue of overtime pay, coup tine, etc. for amergency workers for use not only with exercises, but actual The scheduling of exercise time frames can be disasters and emergencies. In most adjusted so as to preclude significant burdens on volunteers. case conducted outside their normal work hours so they would not have to miss work. Capabilities to ef fect shift changes are critical for any prolonged l emergency response to an accident; therefore; it is necessary to demonstrate this capability.
Will an unannounced exercise have to be curducted with each plant during the six-year period?
Yes, an unannounced exercise will have to be conducted with end plant atThe i least once during the six-year-period.
test the capabilities of exercise players to carry out their emnergency responsibilities in an exercise that approximates the conditions of anHoweve actual radiological emergency. Its intent the need for advance planning for the development of exe play to non-exercise players sud as exercise controllers.
Is there a r.cca for exercises to be held during different seasons over the__
six-year period?
The intent of this requirement in NUREG-9654/ FEMA-REP-1 is to assure tha State and local governments have the capability to mobilize energency response personnel and carry out amergency functions unde:
weather conditions.
capability is often demonstrated in response to winter snow storm the clearing of roads has merit.
poses adeduling problems because of linkages between Accordingly, exercise sche we have ;
and fuel loading needs to be more carefully examined. In the meantime, asked FEMA HQ to reassess the need for this requirement. ,
if a State seeks an exegtfon from this requirement under 44 CFR 358.9(c),the hegion will promptly process it to FEMA HQ for consideration.
'. t Do the requirements of PR-1 apply to host counties? Men will formal Elch criteria be developed for host county plans and exercise objectives?
exercise objectives are state objectives, Which are risk county objectives, and which are host county objectives?
1he key to determining which counties must meet the requirenents of PR-1 is to examine the specific State and local emergency plans for a particular site, m atever exercise objectives are incorporated in an organization's plan must be exercised. While the terminology of " host" and "at risk" counties is not used in NUREG-9654/FDE-REP-1, PR-1 or any other FDE REP guidance, we assume that these terms are being used to distinguish between l those organizations in the pime exposure EPZ and those that are not.
Counties located outside of the pime pathway EPZ's are not required, under any NRC or FDR regulations or guidance, to develop energency plans.
- However, where local governments outside the pitsee EPZ have entered into agreernents with State or local governments within the pitane EPZ to provide services and/or facilities, they could be expected to participate in exercises in which these services and/or faellities are involved in the exercise objectives.
Will off-hour exercises conducted under earlier quidance be " grandfathered" in? For exanple, will the March 1985 Zion exere:,se count as an of f-hour exercise? 1 hat exercise started before 6:00 a.m. to cwply with the then existing draf t guidance but the final guidance says an of f-hour exercise must begin before 4:00 a.m. .
Any off-hour exercises that were conducted in conpliance with the previous guidance (i.e., NUREG-9654/FDE-REP-1) during this six-year period will be grandfathered.
In Mmorandtyn PR-1, paragraph neber 3 of the Attendant criteria of Evaluation Criterion N.l.b. lists several requiresnents for exercising inoestion plans. Which of these requirements apply to Wisconsin?
Two of the three conditions set forth in itan 3 apply to the State of Wisconsin. First, since Wisconsin has three sites located within its border,the State will have to fully participate in the ingestion aspects of an exercise at same site once every six years and partially participate at the other sites within the same six-year period. Second, since Wisconsin has ingestion-related responsibilities for three sites located outside of its border, the State will have to partially participate in ingestion-related exercises for those sites whwnever the host State conducts such exercises.
Do local units of goverment have to develop and exercise ingestion plans?
Memorandtsn PR-1 says that generally local units of goverment do not have to develop an irm estion plan while Menorandtsn IN-1 indicates the requirement I for ingestion planning at the local level.
-As stated in 91 PR-1, States have the primary responsibility for developing However, it is recognized that in and testing ingestion pathway measures.
some States, lomi governments are vested with ingestion-related '
responsibilities. In such cases, they would be espected to exercise these measures in conjunction with the States.
L y
l Doesn't the Annual Iatter of Certifistion (AIC) requirement duplicate l reporting requirements under the Cenprehensive Cooperative Agreements (CCA)?
This requirement may necessitate dupliantive reporting on the same radiological program activities such as drills. Because of this potential ;
conflict, the Offices of Natural and 'hchnological Hazards Prograns and Snergency Management Programs within the state and Local Programs and Support Directorate are considering this proposal: M ere State and local governments have to report to FEMA on the same activities through their CCh's and the REP program, they may report on these activitis through their Atr's and simply reference the Atc report in their CCA report. In the ;
maantime, if an organization is involved in an activity for which it must :
sutnit information in both CCA and AIC reports, then it may report on this I activity in the CCA report and sinply reference the CCA report in the Alf. l l
I hope this information will facilitate your iglementation of the various '
REP program requiresnents. As noted above, I will keep you infonned of FEMA HQ response to the issues identified during our conference. If you have any questions please do not hesitate to contact me.
Sincerely, f
Walla J ver, Chief Technological Hazards Branch ec: Marshall Sanders h
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State of Wisconsin ^=~
Department of Administration er una ng Aeo,ess DIVISION OF EMEMOENCY GOVERNMENT
. Novenber 27, 1985 po ,on,c,83 7 e3 4802 5heboygan Ann ue .uac< son.W scons.n Mad son. Wi S3707 Phone 608.7663232 Mr. Wallace Weaver, Chief
'Itchnological Hazards Branch ,
Federal Deergency Management Agency-Region V {
300 South Wacker Drive - 24th Floor !
Chicago, IL 60606
Dear Mr. Weaver:
Af ter reviewing the final version of Claidance Mernorandum PR-1, Policy on NUREG-0654/IMA-REP-1, and 44 CFR 350 Teriodie Requirements, I foresee several problens in inplementing the menorandum.
It was particularly disappointing to note that the final senorandum indicates the six-year period begins with the first joint (utility, state, and local government) exercise conducted after Novenber 3,1980, the effective date of 10 CFR Part 50, and not with the date of the first exercise conducted for 350 approval which would begin the six-year period after Septenber 28, 1983, the effective date of 44 CFR Part 350, as indicated in the draft version of the menorandum dated April 24, 1985.
I believe that the six-year period should begin with tie first exercise conducted for 350 approval for the follcuing reasons. 'Ibe years 1979 to 1983 was a period of experinentation in the developnent and inplementation of the Radiological Drergency Planning (REP) Program.
112 ring those years, guidance frarn IRA and plan develognent and exercising by the utilities, states, and local units of government were in a formative stage. EmA and the states were learning how to write plans and how to conduct exercises. 'Ibe period was marked by a nunber of changes in FmA guidance and by a lack of unifonnity in the FmA Regions in reviewing plans, evaluating exercises, and preparing interim findings.
It was not until the last half of 1983 that imA began to becczne more consistent in its amroach to the REP Program. Several key documents mark this beginning. Dave McLoughlin's August 3,1983 menorandum to the ImA Regional Directors introduced several important changes in the proceckares all FmA Regions were to use in reviewing radiological emergency plans and for observing, evaluating, and reporting on REP exercises. 'Ibe pernorandtsn introduced the modular format for observing exercises and the list of 35 exercise objectives cross-referenced to specific NUREr, iterns and portions of the exercise observation modules.
'Ibe final publication of 44 CPR Part 350 on Septenber 28, 1983, provided ;
for the regulation of the developient of policies and procedures for review and approval by FMA of state and local radiological emergency response plans and preparedness. On 7%bruary 16, 1984, I m A issued
1 Mr. mile Weaver Nwenber 27, 1985 Page 'two Revision 1 to Guidance Memarandum 17 in an effort to bring further uniformity in preparing for and conducting exercises. 'Ibese three docunents mark the beginning of a truly concenf. rated effort by ITMA to bring uniformity and consistency to REP planning and exercising throughout the IIMA Regions and makes the publication of 44 CfR Part 350 a logical time at which to begin meeting the periodic requirenents.
If Nwenber 3,1980 remains the date that the " clock" starts, Wisconsin will not be able to satisfy the six-year requirement pertaining to ingestion pathway exercises because IIMA has yet to issue final guidance for ingestion planning and exercising. It was not until April of 1985 that FIMA issued a draft of guidance for the ingestion pattway. In light of the lack of uniformity and inconsistency which acconpanied the developent of plume exposure pathway planning guidance, it is only reasonable for the states to await final gaidance before attempting to write formal plans for the ingestion pathway EPZ.
Memoran&z: PR-1 indicates that local governments are not usually required to develop and test ingestion plans while the draft form of Chicanoe Memorands IN-1, 'the Ingestion Pathway, notes the responsibilities of state and local governents to take protective actions and lists a nunber of approaches through which the planning requirements can be satisfied. i thtil IIMA clarifies the nature and degree of involvement of state and ,
local units in ingestion pathway planning, it will be difficult to l develop ingestion plans which can be exercised ard evaluated in a consistent manner. In Wisconsin, there are 33 counties which would be involved in planning for the, ingestion pathway. If final guidance were available at this time, I would project at least a twosyear period to
- conplete ingestion planning for those counties. Furtherwore, it will be inpossible to begin ingestion planning until et least 1986, because we are currently involved in a major revision of the State's Dergency Management Plan.
I also question the requirement to conduct exercises during different seasons of the year in order to have the possibility of exercising under seasonally different weather conditions. ftw can a workable exercise schedule of this type be reached in Region V, given the large nunter of plants in the region? 'Ibe current exercise schedule is closely tied to the plants' refueling s6edule, and has only recently developed to the point dere exercises fit realistically into the schedules of all the organizations involved in the program. Major rearrangement of the exercise schedule may result in severe schediling problene. Pbrtlernere, I question the necessity of this requirenent. 'Ibe major concern with weather problens in this part of the country center around snow and related transportation problens. Each winter, every jurisdiction in Wisconsin demonstrates its ability to keep transportation routes open. l
Mr. Wallace Weaver l Novenber 27, 1985 l Page 1hree i
If winter weather conditions were so severe that snow plows could not be sent out, an evacuation could not be carried out, and protective actions would consist of sheltering in-place. B is requirement should either be eliminated or the routine renoval of snow could be viewed as a separate l drill conducted in support of nuclear power plant exercises.
In its present form, the requirement to conduct unannounced exercises makes little sense. Ibw can any exercise be unannounced when planning for that exercise begins 120 days in advance? Enowing that the exercise will take place within a particalar seven day timeframe does not make the exercise unannounced. Bis only inconveniences the state and local i units of spverrment by introdacing uncertainties and interruptions in j their normal work schedules for one week instead of one day. We and all other parties involved, recognize that this is not a genuine test of our ability to respond. W reover, it is highly disruptive of day-to-day state and county activities and would be very damaging to the cooperative rapport toward the exercise process which has been built up over a nunber l
of years. B is requirement should be eliminated.
In sunmary, I question the validity of several of the requirements.
Further, I foresee great difficulty in meeting a six-year timeframe, ,
beginning Itrvember 3,1980 for successfully ocupleting the 35 exercise / planning objectives which were not spelled out prior to August, 1983. If more realistic solutions cannot be found for several of the i issues I have raised, I also question the advisability of trying to meet these standards and wonder how F1MA and WC would respond to a i deterimination not to comply. ;
I hope that we can have FEMA's response to these concerns and that they i
can be discussed at the exercise scheduling Neeting being planned for January in Oticago. Ikdst separate cover, I will send you a list of
- questions related rare specifically to Wisconsin which I hope you can
) answer.
Sincerely, <
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! id geer ider, Director l l Bureau of Plans and Preparedness i 6
DStjlr ll16C l cc: 5tsn Alt, Deputy Secretary, Dept. of Administration Rick Anthony, FIMA, Battle Creek ,
Region V States l Chrrett Nielsen 1strance Asad l
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- % 20 03g State of Wisconsin O':~
Department of Administration =f;,-
DIVISION OF EMEROENCY OOVERNMENT usa.no Acorns o Post ofi.ce Boa 7865 4802 Sheboygen Avense .Med son.Wiscons'n Mad. son, W153707 Phone 608N UM Rwenber 29, 1985 ,
Mr. Wallace J. Weaver, m ief W logical Hazards Branch Federal Dergency Managenent Agency 300 South Wacker Drive, 24th Floor micago, IL 60606
Dear Mr. Weaver:
As indicated in my letter of Novenber 27, 1985, here are amne questions which Guidance Memoranduns PR-1, feriodic Requirements and IN-1, '!he Ingestion Pathway have raised. 'Ibese questions touch on several planning and exercise activities.
- 1. How can Novenber 3,1980 be used to begin the six-year corpliance period of all exercise objectives when the objectives were not clearly identified or actually used for exercise evaluation until November, 1983?
- 2. When will final guidance be conpleted for ingestion pathway ,
planning? How can the six-year empliance period for ingestion ;
planning and exercising begin in 1980 when draft guidance for ingestion plans were not published until April 5,1985?
- 3. Will an off-hours exercise have to be conducted with each plant during the six-year period?
- 4. Will an unannounced exercise have to be conducted with each plant during the six-year period?
- 5. Do the requirements of Menorandum PR-1 apply to host counties?
- 6. When will formal criteria be developed for host county plans and exercise objectives?
- 7. Will off-hours exercises conducted under earlier guidance be
" grandfathered" in? Pbr exanple, will the March 1985 Elon exercise 1 count as an off-hours exercise? 'Ihat exercise started before 1 6:00 a.m. to comply with the then existing draft guidance but the final guidance says an off-hours exercise must begin before 4:00 a.m. ,
r I
evenber 29, 1985 Mr. Wallace J. Weaver, Chief Page Wo
- 8. Which exercise objectives are state objectives, which are risk county objectives, and which are host county objectives?
- 9. In Mmorandum PR-1, paragraph nunber 3 of the Attendant Criteria of Evaluation Criterion N.l.b. list several requirements for exercising ingestion plans. Which of these requirements apply to Wisconsin?
- 10. Do local units of government have to develop and exercise ingestion plans? Menorandum PR-1 says that generally local units of government do not have to develop an ingestion plan while Menorandum m-1 indicates the requirenent for ingestion planning at the local level.
If you believe, as we do, that these questions would be of interest to all Region V states, we request that they be discussed at the upoaming regional scheduling meeting in Chicago on January 16-17.
Sincerely, .
/ _
Dev d Speer der, Director Bureau of Plans and Preparedness D % 1r lll6C oct 'Itn Alt, Deputy Secretary, Department of Administration Garrett Nielsen Lawrence heed Rick Anthony, Federal Dergency Management Agency, Battle Creek Region V States ,
Illinois Indiana Michigan Minnesota Chio l
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