ML20211J457
| ML20211J457 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/1997 |
| From: | Congel F NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Baughman B Federal Emergency Management Agency |
| References | |
| NUDOCS 9710080128 | |
| Download: ML20211J457 (12) | |
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October 2, 1997 Mr. Bruce P. Baughman, Director Operations and Planning Division Response and Recovery Directorate Federal Emergency Management Agency 500 C Street, SW Washington, DC 20472
Dear Mr. Baughman:
This letter is in response to several memoranda requesting NRC comments on numerous draft documents. These documents include the first draft of the basic Federal Response Plan (FRP), FRP Annexes, and Mission Assignment Overview. The incoming correspondence addressed by this letter is listed in the enclosure. We are providing a consolidated set of comments to ensure a consistent and integrated review of the various parts of the FRP and supporting documents.
Our primary concern is that the FRP does not accommodate the planning for peacetime radiological emergencies as documented in the Federal Radiological Emergency Response Plan (FRERP). We recognize that FEMA intends to address this interf ace in an " Incident Annex." However, we feel that revisions are also needed to the basic plan to recognize the roles of the agencies who willlead the Federal response in accordance with other plans. Please contact Thomas McKenna of my staff via phone (301-415 6073), or e-mail (tjm2@nrc. gov) if you have any questions or comments. Our detailed comments are enclosed.
Sincerely, Original /s/ by F. Congel Frank J. Congel, Director Incident Response Division Office for Analysis and Evaluation of Operational Data -
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Mr. Bruce P. Baughman, Director-Operations and Planning Division Response and Recovery Directorate Federal Emergency Management Agency 500 C Street, SW Washington, DC 20472
Dear Mr. Baughman:
This letter is in response to several memorande reques ' g NRC comments on numerous draft documents to include the first draft of the basi ederal Response Plan, FRP Annexes, and Mission Assignment Overview. We re providing a consolidated set of comments to ensure a consistent and lategrated view of the various parts of the Federal Response Plan (FRP) and supporting document Our primary concern is that the FRP does n accommodate the planning for peacetime radiological emergencies au documented i the Federal Radiological Emergency Response Plan (FRERP), We recognize that FEMA ' itends to address this interface in an " incident Annex." However, we feel that revisi ns are also needed to the basic plan to recognize the roles of the agencies who willle the Federal response in accordance with other plans. Please contact Thomas Mc ' nna of my staff via phone (301-415 6073), or e-mail (tjm2@nrc. gov) if you have any q estions or comments, Our detailed comments are enclosed along with a list of the ' coming correspondence addressed by this letter.
Sincerely,
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Frank J. Congel, Director j
incident Response Division Office for Analysis and Evaluation of Operational Data
Enclosure:
As stated DISTRIBUTION:
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Mr. Bruce P. Baughman, Director Opetutions and Planning Division Response and Recovery Directorate Fedeial Err.orgency Management Agency 500 C Street, SW Washington, DC 20472
Dear Mr. Baughman:
This letter provides the NRC comments on the first draf f the basic Federal Response Plan, FRP Annexes, and Mission Assignment Overvie. Our prirnary concern is that the FRP does not accommodate the planning for peaceti e radiological emergencies as documented in the Federti Radiological Emergency esponse Plan (FRERP), We recognize l
that FEMA intends to address this interface in a Incident Annex." However, we feal I
that revisions are also needed to the basic plan o recognize the roles of the agencies who willlead the Federal response in accordance ith other plans. Please contact Thomas McKenna of my staff via phone (301415 6 73), or e mail (tjm2@nrc. gov) of my staff if you have any quer*Sns or comments. Ot detailed comments are enclosed.
- Sincerely, Frank J. Congel, Director Incident Response Division Office for Analysis and Evaluation of Operational Data
Enclosure:
As stated Distribution:
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NUCLEAR REGULATORY COMMISSION WASHINGf oN, D.C. 30WH001 October 2, 1997 Mr. Bruce P. Baughman, Director Operations and Planning Division Response and Recovery Directorate Federal Emergency Management Agency 500 C Street, SW Washington, DC 20472
Dear Mr. Baughman:
This letter is in response to several memoranda requesting NRC comments on numerous i
draf t documents. These documents include the first draft of the basic Federal Response Plan (FRP), FRP Annexes, and Mission Assignment Overvie. The incoming correspondence addressed by this letter is listed in the enclosure. We are providing a consolidated set of comments to ensure a consistent and integrated review of the various parts of the FRP and supporting documents.
Our primary concern is that the FRP does not accommodate the planning for peacetirne radiological emergencies as documented in the Federal Radiological Emergency Responso Plan (FRERP). We recognize that FEMA intends to address this interface in en " Incident Annex." However, we feel that revisions are also needed to the basic plan to recognize the roles of the agencies who willlead the Federal response in accordance with other plans. Please contact Thomas McKenna of my staff via phone (301415 6073), or e mail (tjm2@nrc. gov) if you have any questions or comments. Our detailed comments are enclosed.
Sincerely, Va' v 1
Frank J. Congel, Dir or Incident Response Division Office for Analysis and Evaluation of Operational Data
Enclosure:
As stated
DETAILED NRC COMMENTS ON THE FIRST DRAFT OF THE BASIC FEDERAL RESPONSE PLAN (FRP), FRP ANNEXES, AND MISSION ASSIGNMENT OVERVIEW Those comments are in responso to the following correspondenco:
1.
July 16,1997 Memorandum for:
Emergency Support Function Leaders Group Federal Responso Plan Support Agenclos From:
Bruce P. Baughman Director, Operations and Planning Division Rosponso and recovery Directorato
Subject:
Federal Responso Plan Updato First Draft 2.
July 25,1997 (Provided to the NRC at the 1997 ESFLG/FRP Support Agency Retreat, August 20,1997)
Memorandum for:
Reglenal Members Document Developers Group From:
Donovan Puffor Chair Disaster Operations Documentation Project
Subject:
Mission Assignment Overview 3.
July 28,1997 Memorandum for:
Frank Congel U.S. Nuclear Regulatory Commission From:
Gary D. Johnson Chief Financial Office
Subject:
Financial Management Annex Comments 4.
August 5,1997 Memorandum for:
Emergency Support Function (ESF) Loadors From:
Bruco P. Baughman Director Operations and Planning Division
Subject:
Tetrorism incident Overview and Annexes i
2 5.
August 9,1997 Memorandum for:
Emergency Support Function Loaders Group and Advisors Fodoral Rosponso Plan (FRP) Support Agencies Representatives From:
Bruce P. Baughman Director Operations and Planning Division
Subject:
Emergency Support Function Londors Group (ESFLG) Action L Information Checklist and Now FRP Public Information Support Annex Draft 6.
August 12,1997 Memorandum for:
Emergency Support Function t.oadors Group Fedotal Responso Plan Support Agencies From:
Bruce P. Baughman Director, Operations and Planning Division Responso and recovery Directorate
Subject:
Federal Response Plan Update First Draft of Basic Plan Comments on the Federal Resoonse Basic Plan. Draft 8/12/97 1.
" Letter of Agreement": Add the following to the second paragraph.
The Federal Responso Plan also describes the unified response with one or more other Fodoral plans.
2.
Page 1, "Purposo": Add the following.
- 6. Describes the relationship with Federal responso efforts under other plans.
3.
Pago 3. Section B, " Scope": The basic plan should focus on general concepts. The basic plan should not contain specific information contained in the " Incident Annexes." Revise paragraph 5 to read: " Additionally, the FRP may be used to provido consequences management support for technical or specialized responses to incidents. This may be provided by Federal agencies responding in accordance with other Federal Plans."
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4.
Page 5, Section D, " Organization": Revise the first sentence of paragraph 4 to delete " authorities and functions outside the scopo of the Stafford Act" because
3 this may not always be true, 6nd delete the reference to the Terrorism Incident Annex. This could be revised to read: "An incident Annex describes the mission, policies, concept of operations, and responsibilities in incidents that require a unified response under the FRP and one or more other Federal plans."
5.
'Page 7, Section A, " Authorities": Revise paragraph 4 to recognize that the FCO will also work closoly with the agencies that have the respons!bility to lead the Federal efforts under othur plans.
6.
Page 9, Section D, "Gecource Coordinatioo*: Revise paragraph 2 to recognize that in addition to the ESF, the FCO will work with the agencies that have the responsibility to lead Federal offorts under other plans.
7.
Page 9, Section D, " Resource Coordination": Revise paragraph 3 to recognize that in addition to the ESF primary agencies, the agencies that have the responsibility to lead Federal etforts under other plans will have a role in coordination of resources.
8.
Page 12, Section 1, " Overview of Typleal Response Sequence": Revise the first paragraph to include, as one of the components, the agencies that have the responsibility to lead Federal efforts under other plans.
9.
Page 13, Section 1 " Overview of Typical Response Sequence": Revise paragraph "e" and "g" to include in the EST and ERT representatives of the agencies that have the responsibility to lead Federal efforts under other plans as appropriate.
10.
Papa 13, Section 1, " Overview of Typical Response Sequence": Revise paragraph "f" w indicate that the FCO will also work with representatives of the agencies that have the responsibility to lead Federal efforts under other plans as appropriate.
11.
Page_14, Section 2, " Emergency Support Functions": Revise paragraph "n" to
' indicate that agencies that have the responsibility to lead Federal efforts under other plans will have the status of a Primary Agency when these plans aru being executed.
-- 12 c Page 14, Section 2. " Emergency Support Functions": Revise paragraph " " to recognize that representatives of the agencies with the responsibility to lead Fe< feral efforts under other plans may have a role in coordination with state and local counterparts in the case of radiological accident, the State counterparts could be different than those used by the ESF.
13, Page 15, Figure 4: Add a column entitled " Peacetime Radiological Emergencies" showing the FRERP LFAs (NRC, DOD, DOE, EPA, NASA) as primary agencies with a note explaining that the primary agency will be the agency with the lead for the event under the FRERP.
14.
Page 19, Section 3, " Emergency Response Team Advance Element": Revise to recognize that, in addition to the selected ESF primary agencies, representatives of w
4 the agencies that have the responsibility t; lead Federal efforts under other plans may be incorporated in the ERT A.
15.
' Page 19, Section 3, " Emergency Response Team": Revise the first paragraph to recognize that, in addition to the ESF primary agencies, representatives of the agencies that have the responsibility to lead Federal efforts under other plans may be incorporated in the ERT.
16.
Page 23, Section 6,~ "Ernergency Support Team": Revise to recognize thst in addition to the ESF, representatives of the agencies that have the responsibility to lead Federal efforts under other plans may be incorporated in the EST.
17.
Page 25, Section D, " Activation": Revise paragraph "1" to include requesting
- representation from Federal agencies that have the responsibility to lead Federal
- efforts under other plans Comments on the Financial Management Annex, Draft Aoril 1997 1.
Acronyms are not always defined, Spell out all acronyms or add definitions, t
2.
Page 5: Why include discussic,n of agency certifying officers? Is the section discussing FEMA certifying officers or all supporting agency certifying officers?
Citation should read, "31 U.S.C. 3528."
3.
The Annex needs to be clearer regarding the flow of documents it appears that FEMA issues a Request for Federal Assistance (RFA) signed only by the " Federal
- Approving Official" (FEMA) to the " primary agency" who then issues a " tasking document" to the support agency W.g., NRC). A *subtasking" document is included in Attachment B. Attachment B presents a form which requires both the "subtasked"_ agency and the " primary" agency to sign, it does not include a cost amount. Recommend that a cost limitation amount be added. Otherwise, the primary agency's reimbursable fund balance could be exceeded, in addition, the "subtasked" agency needs a clear notification of its reimbursable funding level.
4.
Section Vll.B.,_on pages 11 and 12 discuss " Expenditures Eligible for i
Reimbursement." The pages note that overtime and travel of Federal employees is i
telmbursable. Therefore, regular salaries and benefits are probably not reimbursable in addition, the policy on charging overhead is not yet developed.
)-
The policy stated on these pages is inconsistent with NRC's policy of charging full costs for performing reimbursato work, NRC's policy requires charging both salaries and benefits and overhead costs, as well as travel and contractual support costs. Recommend revising this section to permit, consistent with appropriate legal rostrictions, agencies to charge for expenditures in accordance with their individual agency reimbursabla work policies.
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Page 13 states thi.t the information in Paragraph Vll.B.1 should be included on the SF 1080 or SF 1081. This requirement does not make sense since Paragraph Vll.B.1. discusses expenditures eligible for reimbursement.
6.
Page 14: The reference to Attachment D should be changed to Attachment C.
7.
Section IX, " Closeout Procedures," page 21, requires that final billings be submitted within 30 days of the completion or termination of an assignment. Recommend that this be increased to 90 days to permit agencies to process bills from contractors and record expenses in agency accounting systems prior to billing FEMA.
Comments on the Terroristn incident Annex, Draft Februarv 7,1997 The Terrorism Incident Annex to the Federal Response Plan (FRP) should be modified to reflect NRC responsibilities in responding to threats or acts of terronc., for incidents that occur at a facility licensed by the NRC or an Agreement State. These 'esponsibilities are delineated in the Federal Radiological Emergency Response Plan (FRERP).
For radiological emergencies, only the agencies identified by FRERP have the technical expertise and authorities necessary to coordinate the appropriate response with the FBI.
These responsibilition and authorities must be included in the Terrorism Incident Annex if this document is to be used for its stated purpose of describing the concept of operations for responding to terrorist incidents within the United States.
The Terrorism incident Annex is especially misleading in describing FEMA as the lead agency for consequence management in pre incident and trans incident situations. As you know, the purpose of the Federal Response Plan is to address the consequences of any disaster or emergency situation in which thare is a need for Federal response assistance under the authorities of the Stafford Act. The Federal Response Plan is based on the fundamental assumption that a significant disaster or emergency will overwhelm the capability of State and local governments to carry out the extensive emergency cperations necessary to save lives and protect property. For FEMA to assume lead Federal agency responsibilities for incidents where the authorities of the Stafford Act have not been invoked is fundamentally unsound. FEMA does n;t have the technical expertise or authorities necessary to serve in a lead capacity for these situations.
The following revisions are recommended:
1.
Page TI 3, Section A, " Lead Agency Responsibilities": Revise to clearly state that for technical or specialized responses to incidents addressed by other plans, FBI will rely on the agencies identified in these plans to provide technical assistanco. This is consistent with Figure 2.
2.
Page TI 3, Section B, " Consequence Management": Revise to clearly state that for technical or specialized responses to incidents addressed by other plans, FEMA will rely on the agencies identified in these plans to provide technical assistance.
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3.
Pago TI 7,Section IV A, " Crisis Management": Revise to clearly state that for technical or specialized responses to incidents addressed by other plans, FBI will rely on tha agencies identified in these plans to provide technical assistance.
4.
Pago TI 9,Section IV B, " Consequence Management": Revise to clearly state that for technical or specialized responses to incidents addressed by other plans, FEMA will rely on the agencies identified in these plans to provide technical assistance.
5.
Page TI 16, Section C, " Federal Agencies Supporting Technical Operations":
Revised to remove DOE as an intermediatory with the FRERP LFA. Add a sub-section entitled " Lead Federal Agencies under the FRERP." in this section the responsibilities of the LFA will be summarized and the LFAs listed (include FRERP Table Il 1).
Comments on Terrorism Incident. Conseauence Manaaement Ooerations. Overview and Annexes. Draf t August 5.1991 The document must be revised to reflect the NRC responsibility under the Atomic Energy Act of 1954 and its role as LFA under the FRERP. The LFA must be the source of technical assessments and coordination of the facets of the emergency involving actual or potential radiological consequences. This must include accident management, consequence projection, accident mitigation, protective action assessment, Federal responder protection, and interf ace with the facility.
Emeraency Suonort Function #5. Information and Plannina Annex Draft. July 15,1997 1.
Page ESF#5 4, Section 1, " Basic Organizational Structure for the ROC and DFO (the ERT)": Revise paragraph 'd" to indicate that the status reports of the Federal agencies leading Federal efforts under other plans w:ll also be gathered and incorporated into the SITREPs.
2.
Page ESF#5 5, Section B 1, " Basic Organizational Structure for the ROC and DFO (the ERT)": Rovise paragraph "o" to recognize that technical products may be produced by the agencies that have the responsibility to lead Federal efforts under other plans.
3.
Pago ESF#5 5, Section B 2, " Basic Organizational Structure for the EST": Revise paragraph "b" to indicate that the status reports of the Federal agencies leading efforts under other plans will also be gatherod and included in the SITREPs.
4.
Pago ESF#510, Section D, " Essential Elements of Information": Add " status of Federal efforts under other plans" Comments on the Public information Suocort Annex, Draft Auaust 7.1997 Section Ill.A.2 paragraph "a", applies only tc terrorist events. There are other Federal plans for response to technical or specialized events that call for establishing JICs.
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7 Therefore we recommend that this paragraph be revised to be generalin nature, stating
" Federal and local JICs may be established through the execution of other Federal plans or directives (e.g., FRERP)."
Comments on the Mission Assionment Overview Draft Julv 1997 Page 5, "The Mission Assignment Process": Revise the paragrapt at the top of the page-to recognize that the agencies that have the responsibility to lead Federal efforts under other plans (e.g., FRERP) may have a role in determining the best solution to meet an identified need.
Comments on Human Services Suocort Annex Draft July 15,1997 i
Page HS 7, "Section B Other Federal Agencies": Add the following:
NRC and DOE For a nuclear incident at f acilities licensed or operated by DOE or NRC, the following may be provided under the Price Anderson Act Assistance to individuals 1
Assistance to State and local governments Comments on Infrastructure Recoverv Sunoort Annex Draft July 15.1997 Page IN 6, Section 111. "Other Federal Agencies Programs": Add the following:
NRC and DOE For a nuclear incident at f acilities licensed or operated by DOE or NRC, the following may be provided under the Price Anderson Act.
Assistance to individuch Assistance to state and local governments Comments on Mitiaation Sunoort Annex Draft Julv 15,1997 Page MT 4, Section 2, " Support Agencies": Add the Nuclear Regulatory Commission (NRC) as a Support Agency.
Other Annexes The following were reviewed and we have no comment, Emergency Support Function #1, Transport Annex Draft July 15,1997 Emergency Support Function #3, Public Works and Engineering Annex, Draft
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i July 15,1997 Emergency Support Function #4, Firefighting Annox, Draft July 15,1997 Emergoney Support Function #6, Mass Care Annox, Draft July 15,1997 Emergency Support Function #7, Resource Support Annex, Draft July 15,1997 Emergency Support Function #9, Urban Search and Rescue Annox, Draft July 15, 1997 Emergency Support Function #10, Hazardous Materials Annox, Draft July 15,1997 Emergency Support Function #11, Food Annox, Draft JW 15,1997 Emergency Support Function #12. Energy Annox, Draft July 15,1997 Donations Management Support Annox, Draft July 15,1997 The following Annexes were not reviewed and comments will be provided during the next round of review:
Congressional Relations Support Annox, Draft July 15,1997 Occupational Safety and Health Support Annox. Draft July 15,1997 4
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