ML20149M852
| ML20149M852 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/19/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| FRN-52FR45866, RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8802290150 | |
| Download: ML20149M852 (25) | |
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TIERNAN vier Pamotut NUCLEAR ENgmor February 19, 1988 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50.tl7 & 50-316 Comments on NUREG-0654/ FEM A-REP-1, Rev.1, Supplement 1 Criteria for Preparation and Evaluation of Radiological Emergency Resoonse Plans and Preoaredness in Sucoort of Nuclear Power Plants Gentlemen:
The following comments are submitted by the Baltimore Gas & Electric Company in response to Supplement I to NUREG-0654/ FEMA-REP-1, Rev.1. Supplement I provides guidance for the development, review and evaluation of offsite utility radiological emergency planning and preparedness for accidents at commercial nuclear power plants.
It applies to situations in which State and/or local governments decline to participate in the planning and preparedness process for such accidents.
BG&E applauds the NRC/ FEMA efforts in developing and issuing this document in such a timely manner. While the phenomena of non-participation has existed for many years, and been dealt with in varying ways, it is clear that this aspect of emergency planning is new to the regulatory process and deserving of time and attention.
In this spirit, we have enclosed as Attachment I to this letter detailed comments and wording suggestions for specific criteria presented in Supplement I to NUREG-0654.
Additionally, copies of affected pages from the draft Supplement have been annotated to reflect our suggestions and are included.
General concern regarding the draft document includes the apparent contradiction regarding the extent of involvement that a non-participating agency will have in a real emergency response. Contrary to Section I.D.,
Assumptions, there are several instances in the evaluation criteria that call on the offsite response organization to assume responsibility for functions that are normally reserved for State and local agencies (e.g.,
I.G.2.a.;
II. A.2.a.;
II.E.4.;
II.E.6.;
II.E.7.;
II.J.9.;
II.J.10.d.;
etc.).
In many instances, these functions challenge the authority issue of police power. It is our firm belief that adequate offsite response planning can only be realized if the offsite response organization has the legal right to implement its actions. A workable plan can be developed in accordance with Supplement I criteria if these criteria clearly reflect the assumption that State and local agencies will cooperate with the utility to exercise their best efforts to protect public health and safety.
0802290150 % 2 I)lg O
Document Control Desk February 19, 1988-Page 2 A second concern is the endorsement of FEhfA guidance policies, guidance memoranda and REP documents in the draft supplement. Reference to these documents in this manner conveys their subject matter to NUREG-%54, Supplement 1. Consequently, offsite plan development will be impacted by documents that do not receive the same regulatory processing (a formal review, comment, approval and distribution mechanism) as the parent document. Particularly troublesome is the fact that there are existing guidance memoranda that expand NUREG-0654, its draft Supplement I and Federal Regulation.
Additionally, since guidance policies are essentially internal FEh1A documents, the full extent of these is unknown.
Our last general concern is the frequent reference to participating organizations in Supplement 1.
As noted in our attached comments, Supplement I
must address non-participating organizations as defined in Section I. F., Definitions. Participating State and local agencies are subject to criteria in the body of NUREG-0654 and should not be included in Supplement 1.
Baltimore Gas & Electric Company appreciates the opportunity to provide this input. As owner / operator of the Calvert Cliffs Nuclear Power Plant, we share yout interest in establishing a meaningful and workable approach to emergency response where State and/or local officials refuse to participate in planning.
Thank you for your attention to this matter.
Very truly yours, b
l JAT/TEF/DLS/ dim Attachment I
cc:
D. A. Brune, Esquire l
J. E.
Silberg, Esquire R. A.Capra, NRC S. A.hicNeil, NRC W. T. Russell, NRC l
D. C.Trimble, NRC l
D. L.hfeyer, NRC l
l l
k l
l..
NUREG-0654, SUPPLEMENT 1 COMMENTS SECTION PAGE COMMENT I.E.
Scope 2
Delete:
. and the resources to implement the offsite plan must be identified and committed by the utility and by State and local governments participating in the planning process."
Utility offsite plans must account for any participation from State and local organizations. In doing so, NUREG-0654 criteria must be satisfied.
NUREG-0654 criteria requires resource commitments from the
- utility, State and local-agencies; therefore, this statement is not necessary in Supplement
- 1. Eliminating this statement will ensure only two situations exist: either an agency participates and is subject to NUREG-0654 or an agency does not participate and Supplement I must be applied. It will ensure that commitments are not expected from non-participating agencies.
l.E.
Scope 2
Delete: "The appropriate FEMA guidance memoranda, policy memoranda and REP documents (e.g., REP-2, 10, 12) will be applied to define the conditions of adequacy and inadequacy of emergency plans and preparedness for specific evaluation criteria."
It is not appropriate to endorse FEMA policy memoranda, guidance memoranda and REP documents in this manner. By doing so, the guidance in these documents is conveyed to NUREG-0654, Supplement 1, and hence to offsite plan development, without due process of review and comment or the benefit of a formal control mechanism. Particularly troublesome is that there are existing guidance memoranda that expand NUREG-0654 and Supplement I criteria. If this endorsement is not delcted, then all FEMA guidance must be appended to NUREG-0654, Supplement I and be given the same regulatory process (public notice and review and comment) as the parent document. As written, the scope of Supplement 1 is without bounds. This is an untenable situation for offsite plan developers.
I.G.2.a.
3 Delete: "Identification of the functions which require State and location authorization before implementing ( A.2.a.).'
Implicit in this statement is that there will be functions I
carried out by the offsite rctponse organization that are not within its authority to perform. (This implication is enforced by section II. A.2.a.)
The offsite response organization must have the authority to perform all of its functions. Absent this authority, the plan will be inadequate. As noted in Section I.D.,
Assumptions, it is expected that non-participants will exercise their best efforts to protect public health and l
, l l
NUREG-0654, SUPPLEMENT I-COMMENU SECTION PAGE COMMENT safety by cooperating with the utility. Therefore, the offsite response organization does not have to assume police power.
Compensating actions, including the use of liaisons, will be in place to coordinate State and local resources during the response.
II. A.2.a.
6 Delete: "This description shall specify those functions which require... for an anticipated State and local response to an emergency." (inclusive).
As noted above for 1.G.2.a.,
the offsite response organization must have the authority to perform all of its functions. The offsite response plan will be adequate and will meet the intent of 10 CFR Part 50.47(c)(1) and 10CFR50, Appendix - E, section IV.F. (October 29,1987; 52FR42078) by specifying the functions and responsibilities for major elements and key individuals of the emergency response.
The last sentence of section
!!. A.2.a.
contradicts section ~
1.D.,
Assumptions. The offsite plan will be written "assuming" State and local response. Given this assumption, one need not "anticipate" a
State / local response; it will be done inherently.
II. A.2.b.
6 Delete: ".
including those that reserve functions to State and local governments."
By including a legal basis for "authorities" in the offsite
- plan, those authorities reserving functions to government authorities is necessarily included.
The addition of these words (beyond the current NUREG-0654 wording) accentuates a point that could be an issue with non-participating agencies, ll.C.I.b.
7 Delete:
including expected times of arrival at specific nuclear facility sites; A
time estimate for arrival of Federal resources is not necessary. Generally, people are aware of Federal resource locations and travel times to specific sites. This will be
~
adequate. -
NUREG-0654, SUPPLEMENT I -
COMMENTS SECTION PAGE COMMENT II.C.2.b.
7 Delete II.C.2.b entirely.
The licensee is the offsite response organization; therefore, II.C.2.b.
will be satisfied by implementing II.C.2.c.
Utilities should not be burdened with having to send multiple people to State centers. As written, the utility must dispatch -
three people to offsite agencies:
1 "licensee representative" (II.C.2.b.)
- 1 "offsite response organization representative (II.C.2.c.)
1 "offsite response organization adviser and assistant (II.C.S.)
All three roles can be accomplished by one person. The utility should be free to decide on a case basis if additional people are needed.
- Also, II.C.2.b.
addresses criteria applicable to participating governments. This is beyond the scope of Supplement 1.
Licensee actions for participating governments are addressed in the body of NUREG-0654.
II.C.2.c.
7 Change to: "The offsite response organization shall prepare for the dispatch of reeresentatives to principal offsite governmental emergency operations centers.
Reoresentatives will advise and assist State and local officials in imolementine their resoective roles in the resoonse olan."
As noted for II.C.2.b.,
the utility should have the flexibility to decide the number of people to be sent to State / local emergency centers.
By incorporating "advise and assist" verbiage from II.C.S., the intent of the proposed guidance will be met without compromising the plan developers judgement on how best to meet the specific needs of individual offsite response organizations.
II.C.5.
8 Delete II.C.S. entirely.
The intent of II.C.S. will be realized by the proposed change (above) to it.C.2.c. _
NUREG-0654, SUPPLEMENT 1 COMMENT 3 SECTION PAGE COMMENT II.D.4.
9 Delete: "... implementing emergency actions and that provide for advising State and local officials on The addition of these words beyond the current wording of NUREG-0654 is not necessary. The actions elaborated on (i.e.,
implementing emergency actions and advising the State) are necessarily included in "emergency actions."
Singling out these items can imply that a special reference in the offsite plan must be present rather than having this implicitly addressed by accomplishment of response actions.
II.E.4.
10 Delete:
(and to offsite authorities where possible)...."
The offsite response plan and organization is developed under the assumption that offsite authorities will cooperate with the utility to exercise their best efforts to protect public health and safety in the event of an emergency. Given this, it follows that the plan and organization must provide offsite authorities with follow-up messages. This is not an option.
Provision must exist for the plan to be adequate, ll.E.6.
11 Delete:... and FEMA-REP-10)."
As discussed previously (Supplement 1,
section I.E.,
Scope), it is not appropriate to expand NUREG-0654 criteria by endorsing FEMA-REP-10 with Supplement I since FEMA-REP-10 does not receive the same regulatory review as the parent document.
Guidance documents developed by FEMA to aid internal evaluation of offsite plans are not subject to a formal review, approval and distribution control mechanism. Absent this control, there is no assurance that the adequacy of an offsite plan will survive over time.
II.E.6.
I1 Change last sentence to: "The offsite response orgarization shall have the administrative and physical means to act vate the system or. in instances where the response orcanization does not have authority to activate the system. at least the administrative means to activate the system."
While administrative and physical means of activating the Alert Notification System must
- exist, the offsite response organization need not have the ability for both in all instances. If the response organization has the physical means of activation (this requires that they also have the authority 4
- ~
NUREG-0654 SUPPLEMENT 1 COMMEN13 SECTION -
PAGE COMMENT to' activate it), then. they must also have -the administrative means ' to ' activate the system.
If however the response -
organization does ;not have authority to activate the. system -
(i.e.,
police power is ' required), then the organization can only have the administrative means of system activation. The non-participating agent will retain the physical means of activation.
The offsite '
plan will provide that the non-participating agency will be notified at-the appropriate time of the need to activate the system. This agent will
~ f a real emergency based on.
activate the system in th event o
Supplement 1, section I.D. assumptions.
II.E.7 11 Delete: "The prescripted messages should address the various conditions such as the delegation of authority by the State and local governments to the offsite response organization to issue prompt instructions."
It is not logical or rational to assume that any government, State or local, that refuses to participate in preplanning for a
fixed nuclear
- facility, will delegate any authority whatsoever to a utility offsite response organization.
II.E.7.
11 Change the 4th sentence to: 'Such messages thould include the appropriate aspects of sheltering, ad hoc resoiratory orotec-liQD,e.g.,..."
This appears to be a simple omission from original NUREG-0654 verbiage.
II.E.8.
12 Delete: ".
participating and Supplement I pertains to non-participating governments only.
Criteria for participating governments are addressed in the body of NUREG-0654.
II.G.I.e.
14 Delete: "special steps to be taken to describe These words, under the planning standard Public Education &
Information and the introduction addressed in section ll.G. I.,
give the implication that there will be some actions on the part of the public because of the State's non-participation.
Information disseminated to the public should include the role of the offsite response organization vs.
the State / local organizations, it need not address any "special steps" per se. _ _____________
NUREG-0654, SUPPLEMENT I COMMENT 3 SECTION PAGE COMMENT ll.J.9.
18 Change the 1st sentence to: "The offsite response organization shall establish I,he means to imolement protective measures based upon protective action guides and other criteria."
Physical implementation of protective actions for the public is a function reserved for State and local officials. Offsite response organizations will not have the authority to implement protective measures.
Therefore, the offsite plan must establish the administrative means of implementing the actions via the proper authorities. The word change above will allow for this. This change is needed because "capability" connotes administrative and physical ability to implement an action.
II.J.9.
18 Delete: "The offsite response organization shall describe the means for recommending protection action to the public, for activating the alert and notification system, and for notifying the public of protective action recommendations."
This verbiage is an expansion of existing NUREG-0654 wording and is not necessary. Communication with-the public is adequately addressed in Supplement 1
section ll.E.,
Notification and Procedures and in section II.J.10.c.
II.J.10.d.
18 Delete: "These means sha'.I include notification, support and assistance in implementing protective measures where appropriate."
As mentioned for ll.J.9.,
the notification aspect of this criteria is redundant to Supplement 1
section II.E.
and II.J.10.c.
and, therefore, is not necessary. The remaining aspects, suprmt and assistance, are an expansion of NUREG-0654 criteria. Support and assistance for the mobility impaired are handled by resources available to a State and local community on a day-to-day basis. These resources will be brought to bear by the State and local officials in the event of an actual emergency under Supplement 1 section I.D.I.c. assumption.
II.N.I.b.
24 Change 2nd sentence to: "This includes the demonstration of offsite response organization capabilities un to 1br interface with non-participating State and local government..."
Given that the exercise does not include stand-ins for the anticipated State end local response, the interface with them cannot be demonstrated.
During an
- exercise, the offsite organization will demonstrate capabilities un _..in this interface.
?
NUREG-0654, SUPPLEMENT 1 COMMENTS l
SECTION PAGE COMMENT II.N.I.b.
24 Change 4th sentence to: "The scenario should be varied from exercise to exercise such that all major elements of the plans and preparedness organizations are tested within a six-year period."
The option should be available to not vary the scenario. This will allow major elements of the plan to be tested as often as desired, but not less than once per six years.
II.N. I.b.
24 Change 6th sentence to: "Exercises should be conducted during different seasons of the year" Given that the basis for this criteria is to experience the weather differences of each season, then flexibility should exist for utilities located in areas that do not have four distinctive weather patterns.
Many regions have significant j
weather changes between summer and winter only. Requiring exercises in each season will pose an additional burden on i
exercise scheduling for the utility, NRC, FEMA and any participating State or local agencies. The benefit derived from this will be insignificant.
i II.N.2.a.
24 Delete: "If practicable, attempts should be made to include non-participating organizations in the monthly communications drills."
Repeated attempts to involve non-participating agencies in emergency response plans can lead to further hostilities l
between them and the utility. As noted in Supplement 1,
section II.F., contact with non-participants will be by nurmal telephone numbers. Since normal telephones are used regularly at both communication ends, there will be little benefit derived from monthly tests with non-particip:.nts.
II.N.6.
26 Delete II.N.6. entirely.
As noted for li.N 2.a.,
repeated attempts to involve non-
)
participating agencies in emergency response plans can lead to further hostilities between them and the
- utility, it is incumbent on the utility pursuant to 10CFR50.47(cXIXil) to I
demonstrate to the Commission that it has made a sustained, good faith effort to secure the support of non-participating State and local officials. Without this demonstrated effort.
i the utility would not be authorized to apply Supplement l planning criteria.
l l
l u.
.9 NUREG-0654,5UPPLEMENT 1 '
COMMEN11 SECTION PAGE COMMENT II.O.l..
27-Delete 3rd sentence erttirely and footnote 1.
If mutual aid agreements exist between the local agency and the
- utility, then the agency does not qualify as a
non-participating agent. Therefore, they are outside the scope t
of Supplement I criteria.
1 II.O 4.k.
28 Delete II.O.4.k.
entirely.
r Personnel responsible for interfacing with State and local responders are those people addressed in sections ll.O.4.a.,
- b., c.,
d.,
f.,
s.,
- h. and J. The offsite organization cannot do these functions without State and local responders.
4 II.O.6.
. 28 Delete II.O.6. entirely.
As noted for li.N.6.,
animosities between non-participating State and local officials and the utility will be heightened with repeated petitions for involvement. : The utility must 1
exercise a sustained effort to get State and local support pursuant to 10CFR50.47(cXIXii).
Regarding "other organizations:',
other organizations (i.e.,
participating organizations) are offered training under training criteria addressed in NUREG-0654 proper.
I h
1.
-g-
For Comment l
0.
Assumptions The following NRC/ FEMA assumptions are used for the development, review and evaluation of utility offsite plans and preparedness.
1.
In an actual radiological emergency, State and local officials that have declined to participate in emergency planning will:
a.
Exercise their best efforts to protect the health and safety of the public; b.
Cooperate with the utility and follow the utility offsite plan-and
{
i c.
Have the resources sufficient to implement those portions of i
the utility offsite plan where State and local response is i
necessary.
Although it is assumed that non participating State and local organizations will respond and follow the utility's offsite plan, it is not assumed that these organizations will be as familiar with the plan as if they had par-ticipated in the planning process and exercised with the utility.
There-fore, the utility's offsite response plan and the offsite response organi-zation will provide compensating actions through the use of liaisons to deal with the coordination of information and resources with State and 4
i local governments and to provide advice and assistance to responding State and local governments in implementing their assigned roles and func-tions under the utility's offsite response plan.
E.
Scope In developing this document, the planning standards of NUREG-0654/ FEMA-REP-1, Rev. I have not been changed and they apply to the offsite response organization defined celow.
This complies with the NRC rule change cited in C. above.
The guidance will be used for the development, review and evaluation of offsite emergency plans and preparedness in which State and/or local governments decline to participate in emergency planning and preparedness.
The planning standards are the same as those used to eval-uate licensee, State and local plans and preparedness.
The evaluation criteria have been modified with due allowance for the non participation of State and local governments and for the compensatory measures that must be proposed, developed and implemented by the utility.
The utility offsite plans and preparedness will be expected to account for the vary-ing degrees of participation that the utility is able to gain from State and local organizations during the planning process; r d the rc:O rre: te N 5!f!_$ Y 0$N N; $ "5. N _N.N59)!bEbf b EI!N!'i$ b h __4
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- :i: n: h:ti r crit:ric.
The numbering pattern for the evaluation criteria in this document is the same as thet used in the existing Sec-tion II of NUREG-0654/ FEMA-FEP-1, Rev. 1.
Therefore, numbers that apply to licensee-only evaluation criteria are missing and additional criteria have been assigned new numbers.
2
i For Comment 3
F.
Definitions The following definitions apply to the use of this document.
1.
Offsite Response Organization (ORO):
The utility offsite emergency response organization along with other participating voluntary and private organizations, and local, State and Federal governments engaging in the development of offsite emergency plans and prepared-ness for a nuclear power plant.
2.
Nonparticipating Organization:
Those organizations including State and local governments that decline to participate in emergency plan-ning and preparedness for a nuclear power plant.
G.
Summary of Changes The following is a summary of the changes to the evaluation criteria of NUREG-0654/ FEMA-REP-1, Rev. 1.
1.
The concept of "offsite response organization" is adopted and defined, i
Throughout the revised evaluation criteria "offsite response organiza-tion" replaces references to State and local governments.
2.
In addition, evaluation criteria were modified or added to compensate 3
for lack of participation by State and local governments in the i
i planning process, for these functions:
Id:nti'f::t!:r :' th: functi::: 31e r:;uir; it:t: :nd '0::'
- th:rf::tter 5:ftr: 'rf :n:ntf ;;; (^,. 2. :. ).
b.
Provision of additional personnel to advise and assist State and local officials in an emergency (C.5.).
c.
Provision for advicing State and local officials on emergency actions to be taken (D.4., J.10.f.).
d.
Provision for coordinating emergency messages with State and local governments (E.8.).
e.
Provision for communications with non participating State and i
local emergency operations facilities (F.1.).
f.
Provision for public information describing the role of the offsite response organization vs. the State and local organiza-tions during the emergency (G.1.e.).
s g.
Establishment of an emer0ency operations cente' for use in directing and controlling offsite response functions (H.3.).
h.
Offsite response organization shall have the administrative and physical means (even though they might not have the responsi-bility) for activating the alert and notification system (E.6.
and J.9.).
3
For Comment Control.
The description of these functions shall include a clear and concise summary such as a table of primary and support responsibilities using the agency as one axis, and the function as the other.
T'i: d:::ripti: :h:1? :p;;if3 th::: fun:ti:n:
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't 9:n::' ; b:tructien: 'rer put!!: r::du:3;, 'n:1; ding t:;
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- n; pr:t::tiv: ::ti:n: fer th: p1;:: :ng::;r: p:t hu:3,
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- nd:t';n: t; th; ;;tli
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' ; pr:tectiv: ::ti::: f:r th 'n;;;ti;r :xp;;;r; p;tha;;,
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' :t :n EOC, r:!:::t' r ::nt:r: :nd th: C.Z ;;r'r:t:r;; :nd
'h: :ff:it: pl:r 05:1' :100 id:n t i f) :f '1:r functi:n: :nd
-r::;: :'bt!:: :nd 4-terf:::: f:r :: :rticip:t:d St:t: :nd
^1;;;l r :;:n:: i: er :::r;:n:3 b.
The offsite plan shall contain where applicable (by reference to specific acts, codes or statutes) the legal basis for such authorities,'nc',ud' ; t'::: th:t r:::r;; functi:n: t: Stot; ;nd
__._____s 3.
The offsite plan shall include written agreements referring to the concept of operations developed between Federal agencies, the offsite response organization, and other support organizations having an emergency response role within the Emergency Planning Zones.
The agreements shall identify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and spe-cify the arrangements for exchange of information.
These agreements may be provided in an appendix to the offsite plan or the offsite plan itself may contain descriptions of these matters and a signature
{
page in the offsite plan may serve to verify the agreements.
The signature page format is appropriate for organizations where response i
l functions are covered by laws, regulations or executive orders where separate written agreements are not necessary.
4.
The offsite response organization shall be capable of continuous (24-hour) operations for a pro' acted period.
The individual in the offsite response organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title, i
6 j
h g.
For C:mment B.
Onsite Emergency Organization (Not Applicable)
C.
Emergency Response Support and Resources Planning Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.
l Evaluation Criteria 1.
The Federal government maintains in-depth capability to assist li-censees, States and local governments through the Federal Radiolog-ical Emergency Response Plan.
Each offsite response organization and licensee shall make provisions for incorporating the Federal response capability inte its operation plan, including the following:
a.
specific persons by title authorized to request Federal assist-ance; see A.1.d., A.2.a.;
b.
specific Federal resources expected, ' : hding :n;::ted tir:: :f
- r '
- ! :t p::!'M wele - faci'ity :ite:;
rd i
i c.
specific licensee and offsite response organization resources available to support the Federal response, e.g., air fields, command posts, telephone lines, radio freo"encies and tele-communications centers.
2.
a.
The offsite response organization may dispatch representatives to the licensee's near-site Emergency Operations Facility.
(Technical analysis representatives at the near-site EOF are preferred.)
b.
'5
'i::n::: 05:!' pr:;:r: S r th; di:;:tch :f c prc::nt:tiv;;
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- nter :nd to pr ncip:1 :::r; ncy Oper:tt::: ::nt:r: Of p:rtici-i p;t!,; :nd 70 p:rt!:!;:tfn; g:;:r :nt:.
c.
The offsite response organization shall prepare for the dispatch of e-representativ to princ pal offsit9 governmental pmergency vg h' r resPMive (*q%e. { dvidaA ppc&ws a:%
dAKly opgrationscenters c6 ua.tb itGmhne s 'irdfe rMonu an-
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3.
The offsite response organization shall identify radioTogic 1 labora-i tories and their general capabilities and expected availability to provide radiological monitoring and analyses services which can be used in an emergency.
4.
The offsite response organization shall identify nt.: lear and other facilities, organizations or individuals which can be relied upon in an emergency to provide assistance.
Such assistance shall be iden-tified and supported by appropriate letters of agreement.
7
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For Comment D.
Emergency Classification System f
Planning Standard i
A standard emertjency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Evaluction Criteria 3.
The offsite response organization shall establish an emergency classi-fication and emergency action level scheme consistent with that established by the facility licensee.
i 4.
The offsite response organization should have procedures in place that provide for ' ;1:::ntin; :::r;:n:3 ::ti:n: :nd th:t pr;;id: ;r
- d.i
- in; St:t: :nd 1:::1 Of'fri:1: : emergency actions to be taken which are consistent with the emergency actions recommended by the nuclear facility licensee, taking into account local offsite condi-tions that exist at the time of the emergency.
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For Comment E.
Notification Methods and Procedures
. Planning Standard Procedures have been established for notification by the licensee of State and local response organizations and for notification of emergency per-i' sonnel by all response organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the 4
populace within the plume exposure pathway Emergency Planning Zone have been established.
Evaluation Criteria 1
1.
The offsite response organization shall establish procedures which describe the bases for notification of all response organizations i
4 i
consistent with the emergency classification and action level scheme set forth in Appendix 1 of NUREG-0654/ FEMA-REP-1, Rev. 1.
These procedures shall include means for verification of messages.
The specific details of verification need not be included in the offsite plan.
2.
The offsite response organization shall establish procedures for alerting, notifying, and mobilizing emergency response personnel.
3.
The licensee in conjunction with the offsite response organization
^
l shall establish the content of the initial emergency messages to be l
sent from the plant.
These measures shall contain information about the class of emergency, whether a release is taking place, poten-tially affected population and areas, and whether protective measures l
may be necessary.
4.
Each licenseo shall make provisions for followup messages from the facility to the offsite response organization ' nd t: :ff;it nth; itin 5::: ;;;;iM :) which shall contain the following information if it is known and appropriate:
a.
location of incident and name and telechone number (or communi-cations channel identification) of ca-
+
b.
date/ time of incident; c.
class of emergency; d.
type of actual or projected release (airborne, waterborne, surface spill), and estimated duration /impac+. times; e.
estimate of quantity of radioactive material released or being released and the points and height of releases; f.
chemical and physical form of released material, including estimates of the relative quantities and concentration of noble gases, iodines and particulates; 10
For Comment g.
meteorological conditions at appropriate levels (wind speed, direction (to and from), indicator of stability, precipitation, if any);
h.
actual or projected dose rates at the boundary; projected inte-grated dose at site boundary;
}
i.
projected dose rates and integrated dose at the projected peak and at 2, 5 and 10 miles, including sector (s) affected; j.
estimate of any surface radioactive contamination inplant, onsite or offsite; k.
licensee emergency response actions underway; 1.
recommended emergency actions, including protective measures; m.
request for any needed onsite support by offsite organizations; and n.
prognosis for worsening or termination of event based on plant information.
5.
The offsite response organization shall establish a system for dis-seminating to the public appropriate information contained in initial and followup messages received from the licensee including the appro-priate notification to appropriate broadcast media, e.g., the Emergency Broadcast System (EBS).
6.
The offsite response organization shall establish administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone (see Appendix 3 of NUREG-0654/ FEMA-REP-1, Rev. 1 rd rE"> oEB-10).
It shall be the licensee's responsibility to demonstrate that such means exist, regardless of who implements this requirement.
The offsite response organization shall h ve thqn admini tr tive and p1ysi al means t activate the system leMIR ahk\\ ra. JC, tNh5 bo MC,%85 nW-7.
The offsite response organization hall provide written messages
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intended for the public, consistent with the licensee's classifica-tion scheme.
In particular, draft messages to the public giving instructions with regard to specific protective actions to be taken by occupants of affected areas shall be prepared and included as part of the offsite plans.
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T role of the licensee is to provide supporting information for the messages.
For ad hoc respiratory protection see "Respiratory Protective Devices Manual" American Industrial Hygiene Association, 1963 pp. 123-126.
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.For Comment-~
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There.shall.be provisions for coordinating emergency messages with' az
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non participating State and local governments.
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For Comment 4
4 G.
Public Education and Information Planning Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions shall be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the i
principal points of contact with the news media for dissemination of informa-tion during an emergency (including the physical location or locations) are 4
established in advance, and procedures for coordinated dissemination of infor-2 mation to the public are established.
1 Evaluation Criteria 1.
The offsite response organization shall provide a coordinated periodic (at least annually) dissemination of information to the public regarding how they will be notified and what their actions should be in an emer-gency.
This information shall include, but not necessarily be limited j
to:
educational information on radiation; a.
b.
contact for additional information; protective measures, e.g., evacuation routes and relocation centers, c.
sheltering, respiratory protection, radioprotective drugs; i]
d.
special needs of the handicapped; and 74 e.
- p : M :tep: te be t r t: d:::r'b: the role of the offsite re-sponse organization vs. the State and local organizations during the emerger.cy.
Means for accomplishing this dissemination may include, but are not necessarily limited to:
information in the telephone book; posting in public areas; and publications distributed on an annual basis.
2.
The public information program shall provide the permanent snd transient adult population within the plume exposure EPZ an adequate opportunity to become aware of the information annually.
The programs should include provision for written material that is likely to be available in a resi-dence during an emergency.
Updated information shall be disseminated at least annually.
Signs or other measures (e.g., decals, posted notices, or other means, placed in hotels, motels, gasoline stations and phone booths) shall also be used to disseminate to any transient population within the plume exposure pathway EPZ appropriate information that will be helpful if an emergency or accident occurs.
Such notices should refer the transient to the telephone directory or other source of local emergency information and guide the visitor to appropriate radio and television frequencies.
3.
The offsite response organization shall designate the points of contact and physical locations for use by news media during an emergency.
This should include provisions for accommodating State and local g)vernment public information personnel assigned a role under the offsite plan, 14 i,
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- da For Comment J.
Protective Response Planning Standard A range of protective actions have been deseloped for the plume exposure path-way EPE for emergency workers and the public.
Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure path-way EPZ appropriate to the locale have been developed.
Evaluation Criteria 2.
Each licensee and offsite response organization shall make provisions fo-evacuation routes and transportation for onsite individuals to some suit" able offsite location, including alternatives for inclement weather, high traffic density and specific radiological conditions.
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l 9.
The offsite response organization shall establish agtion guides and
- pabili for imple y
enting protective measures based upon protective ac criteria.
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1:rt and not!'* f t ti:n cy;to, 2nd for notifying the pdli Of pr:t : tic: ::-
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This shall be consistent with the recommendations j
of EPA regarding exposure resulting from passage of radioactive airborne i
plumes (EPA-520/1-75-001), and with those of DHHS/FDA regarding radioac-tive contamination of human food and animal feeds as published in the Federal Register on October 22, 1982 (47 FR 47073).
10.
The offsite response organization's plans to implement protective measures for the plume exposure pathway shall include:
Maps showing evacuation routes, evacuation areas, preselected radio-a.
logical sampling and monitoring points, relocation centers in host areas, and shelter areas (identification of radiological sampling and monitoring points shall include the designations in Table J-1 of hUREG-0654/ FEMA-REP-1, Rev. 1 or an equivalent uniform system described in the offsite plan);
b.
Maps showing population distribution around the nuclear facility.
This shall be by evacuation areas (licensees shall also present the information in a sector forraat);
c.
Means for notifying all segments of the transient and resident population; a
d.
Means for protecting those persons whose mob',lity may be impaired due to such factors as institutional or other confinement.
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+c 0 pproprictc; Provisions for the use of radioprotective drugs, particularly for e.
emergency workers and institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult, including quantities, storage, and means of distribution; 18
r For Comment e
N.
Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emer-gency response capabilities, poriodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of
- j exercises or drills are (will be) corrected.
Evaluttion Criteria i
~
1.
a.
An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency pre-paredness plans and organizations.
The emergency preparedness exercise shall simulate an emergency that results in offsite radio-logical releases which will require response by offsite response organizations.
Exercises shall be conducted as set forth in NRC and j
FEMA rules.
b.
An exercise shall include mobilization of offsite response organi-zation resources adequate to verify the capability to respond to an
~
accident scenario requiring response.
This i ofoffsiteresponseorganizationcapabilitie(glydesthedemonstration opnterfacewithnon-participating State and local government, but oes not include the use a
of standins for the anticipated State and local response.
The offsite response organization shall provide for a critique of the biennial
.l exercise by Federal and offsit ponse organization observers /
1 evaluators.
The scenario aried from exercise to exercise l
such that all major elements o the plans and preparedness organiza-tions are tested within a six year period.
Each organization shall make provisions t start an exercise between 6:00 p.m. and 4:00 a.m.
Exercises a
conducted during different seasons of the year.
At least one exercise shall be unannouncad.
2.
A drill is a supervised instruction period aimed at trsting, developing and maintaining skills in a particular operation.
ill is often a component of an exercise.
A drill shall be superviseu and evaluated by a qualified drill instructor.
The offsite response organization shall conduct drills, in addition to the biennial exercise at the frequencies indicated below:
a.
Communication Drills Communications between the licensee and the 6ffsite response organiza-tion within the plume exposure pathway Emergency Planning Zone shall be tested monthly.
Communications with Federal emergency response organizations and offsite response organizations within the ingestion j
pathway shall be tested quarterly.
Communications between the nuclear i
facility, offsite response organization's operations centers, and 4
field assessment teams shall be tested annually.
Communication drills shall also include the aspect of understanding the content of messages.
I' prc:ti: d le, :tt::pt: :h:uld b; =d: to includ: ner particip:tiq; cr;;;ri:: tion: '- the month!) :: m nicati n: dr!:.
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5.
The offsite response organiz:stion shall establish means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions.
The offsite response organization shall establish management control used to ensure that corrective actions are implemented.
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.._.mm For Comment O.
Radiological Emergency Response Training
. L' Planning Standard
{
~ Radiological emergency resp.onse training is provided to those who may be called on to assist in an emergency.
Evaluation Criteria 1.
The offsite response organization shall assure _the training of appropri-ate individuals.
The offsite response organization shall participate in and receive training.
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4.
The offsite response organization shall establish a training program for 1
instructing and qualifying personnel who will implement radiological emer-gency response plans.2 The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories:
a.
Directors or coordinators of the response organizations; b.
Personnel responsible for accident assessment; c.
Radiological monitoring teams a radiological analysis personnel;
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Police, security and fire fighting personnel; f.
First aid and rescue personnel; g.
Local support services personnel including Civil Defense / Emergency Service personnel; h.
Medical support personnel; j.
Personnel responsible for transmission of emergency information and instructions; and
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5.
The offsite response organization shall provide for the initial and annual retraining of personnel wit;1 emergency response responsibilities.
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