ML20195G027
| ML20195G027 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1986 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20195G032 | List: |
| References | |
| FOIA-88-54 NUDOCS 8703160357 | |
| Download: ML20195G027 (2) | |
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Of.C 2 4 WS6 MEMORMDUM FOR:
James M. Taylor. Director 0
Office of Inspection and Enforcement FROM:
Thomas E. Murley, Regional Administrator Region I
SUBJECT:
SCOPE OF FULL PARTICIPATION EMER6ENCY EXERCl$ES During the recent Federal Radiological Emergency Capability Conference and the Early Emergency Responders Workshop conducted in Region I,
several participants expressed their concerns that the biennial full participation emergency plan exercises do not effectively test emergency response capabilities and unnecessarily increase general pubite apprehension regarding nuclear power plant hazards.
These concerns apparently evolve from the FEMA implerwntation of an un-written policy that all or nearly all full participatien exercises involve a scenario that requires evacuation of a large part of the amergency pluning zone.
In fact most members of the public refer to the emer plan as an "gency exercises as "evacuation drills" and to the State emergency evacuation plan".
Unfortunately, the correlary to this concern is that any radiation exposure, no matter how little, must be avoided by evacuation.
The requirement that exercise scenarios must 1.1volve large scale evacuation establishes limits on the scope of testing of licensee and State decision making capabilities. An emergency requiring evacuation could only result from sequence of very low probability multiple system failures witch lead to a
serious core damage and loss or potential loss of the containment. This fact, when taken in concert with the requirement on scenario content, precludes decision making capability testing for all but the most unrealistic sequences.
State decision makers know that the exercise is going to eventually require evacuation, so other protective actions do not receive serious consideration, in many int.tances the evacuation is conducted well before any serious threat exists for this very reason.
Licensee decision makers know they will not be allowed to prevent core damage, and therefore, half-heartedly fight it and similarly do not give options other than evacuation serious consideration.
More realistic exercises would involve a wider range of Itcensee rispenses to equipment failures and more thorough consideration of sheltering as a reason-able protective action, and would also serve as an indication to the public that evacuation is not always necessary in the event of a reactor accident, l
even if some exposure to radiation is involved.
The requirements for biennial full participation exercises are set forth in 10 CFR 50 Appendix E, Section F. "Training".
In the case of routine biennial full participation exercises, the regulations require that:
Each licentet at each site shall exercise with offsite authorities such that the state and local government emergency plans for each operating reactor site are exercised biennially with full or partial participation
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tslittsglocal governments within the plume exposure pathway EPZ.
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Ol' Jarnes M. Taylor 2
1 A footnote defines "Full participation" as follows:
Full participation includes testing the major observable portions of onsite and offsite emergency plans and mobilization of State, local, and the capability to respond to the accident scenario. lice j
Based on cur inquiries, there appears to be no consistent policy between Regions 1 II, and 111 regarding whether simulation is necessary for each full participation exercise. evacuation decision m tative of FEMI. I indicated that it would probably be appropriate to only t A represen-I the State and local plans to the point of evacuation every other exercise (every 4 years), forcing the serious consideration of sheltering as a v protective action during the other exercise.
that 4 years is too long an interval to wait to evaluate the evacuation which they consider to be the most important and most difficult to jap'le part of the off-site plans.
unavailable for coment at the time this was written).(A knowledgeab In general, the states and utilities develop scenarios which they know will satis fy the most restrictive interpretation of the regulations, and this includes large scale evacuation, this issue be discussed with FEMA Headquarte a
draft a Guidance Memorandum which would specifically require period stration of the full range of reasonable evacuation, sheltering or no protec+ive action at all. protective actions, including observers, outside the scope ofto assess the state's evacuation pla If it is still desired the scenario, after the appropriateness.
timeliness and effectiveness of decision has been evaluated.
comunication of the protective action i
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Thomas E. Murley Regional Administrato ec:
V. Stello, HQ J. H. Sniezek. HQ J. N. Grace. Ril i
J. G. Keppler, Rll!
J. B. Martin, RIV R. D. Martin, RV H. R. Denton, NRR E. S. Beckjord, RES
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