ML20247G491
| ML20247G491 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/11/1989 |
| From: | Donovan R Federal Emergency Management Agency |
| To: | Krimm R Federal Emergency Management Agency |
| References | |
| RTR-NUREG-0654 OL-I-MAG-065, NUDOCS 8905300415 | |
| Download: ML20247G491 (6) | |
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va Federal Emergency Management Agency Region X FederalRegionalCenter Bothou,Washm8 ton 98 19
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l NEMORANDUM FOR: Richard W. Krtaa Assistant Associate Director N gural and T ological Nasards Prograse SL-NT JIMad d.
FRON:
Richard W. Donovan RAC Chairman for the Review of the Seabrook Plan and Preparedness for Massachusetts Consunities
SUBJECT:
Assumptions and Interpretation of Adequate (NUR80-0884/FINA-REP-1, Rev. 1. Supp. 1)
Earlier this week I had conversations with your staff regarding the interpreta-tion of the assumptions used for the development, review and evaluation of
. Utility Offsite Plans and Preparedness.
Following is a discussion of the issues:
NUREG-0654-FEMA /RSP-1, Rev. 1, Supp. 1 states the following assumption will be used for the development, review sad evaluation of Utility Offsite Pleas and
. Preparedness:
"In an actual radiological emergency. State and local officials
'that have declined to participate in energency planning will exercise their best efforts to protect the health and safety of the public: cooperate with the utility and follow the Utility offsite Plan; and have the resources sVfficient to implement those portions of the Utility Offsite Plan where State and local response ir necassary."
(Part I, section C of Supp. 1).
Part 1. Section 8 of supp. 1 states the twquirement that Utility Offsite Plant specify the competsstory necsures that autt be proposed, developed. And laplemented by the utility in order to offset the non-participation of State and 1ecal governments.
'"his section goes on to state that the resources to implement the Utility Offsite Plaa suet be identified and cosaitted by the utility and participating State and local governesats.
Part 1. Section 0 of supp. 1 lists those evaluation criteria of NUR34-0444-FEMA / REP-1, Rev. 1 that were modified or added to compensate for the lack of participation by State and local governments. Most of these specific criteria elements reference response functions that deal with the legal authority issues which FINA's office of the General Council provided to the working group responsible for the development of the Supp. 1 docuneat. None of these criteria reference the use of State and/or local resources that the offsite response organization could identify and rely upon as part of its resposee effort (personnel, equipment, and facilities).
8905300415 890411 PDR ADOCK 05000443 O
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f In suasary, supp. 1 is' intend:d for ths development, revies and evalustion of Utility offsite Plans and Preparedness. The utility must provide compensating actions to offset the non-participation of state and local governments.
Supp. 1 states that the Utility Offsite Plan aunt identify the resources to implement the offsite plan. These resources (personnel equipment, and facilities) aust be-committed by the utility and the participating state and local governments 1.e..
.the FEMA review, evaluation,'and finding, nuet find that sufficient resources have been,1dentified and consitted to implement the Utility offsite Plan and that the Utility Offsite Plans and Preparedates meets the criteria specified la supp. 1, appropriate FINA guidance assorandum, etc.
As my conversations with your staff indicated. I received several phone calle free Region I RAC seabers (who.are also members of FEMA Region II RAC) who had attended a FEMA Region !! RAC aceting last week. At that meeting there was discussion on the~ review of the shoreham Plan (R7. 5) against the supp. 1 criteria. They left that meeting with the following uns retanding:
In determining the fact thas.a evaluation criteria was adequate or inadequate, the Utility Offsite Plan did not have to identify and consit sufficient resources (personnel, equipment, and facilities) because the assunk lons make the response adequate (state and local governments would respond with sufficient resources where state and local response is necessary).
I advised these FINA Reglun ! RAC members that I interpreted supp. 1 differently:
1.e., supp.1 (Part 8, page s) states the Utility Offsite Plan aust identify and
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commit the resources (personnel equipment, and facilities) to be used by the utility and participating state and local governments, and unless otherwise indicated, the only interpretation they should place upon " resources" of
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non-participating state and local governments le "lessi authorittee."
In developing supp. 1 FINA took the position that we do not have a charter to review and evaluate the resources and preparedness of nea-participatlag state and local governments. Therefore, if FINA places the broad laterpretaties se the efficacy of the resposee asenaption and the laplied adequacy of non-participattag state and local government's response and resources, we would be beslag oar review, evaluation, and FEMA fladias os conjecture (the noenapties of adegascy of the non-participating state and local government resources).
In addities, the beste cf FEPA's review and evaluaties sauld ceaflict with the statenest la sapp.
1, "The Utility offeite Plane and Preparedases will be espected to acceent for tho varying degrees of participation that the stility is to gain trea State and local orgerisatione daring the pleaning procese and the reconn es to impletent the Utility ofisite Plan must be identiftad and committed by the utility and by state l
l and local gov nam o ts participatics la the plamaing prosess."
At this potat, I would like to digrees to e differect subject, but identical Isoce: 1.e., laterpretation of supp.1's asuusption la regard ts FENA's review, evaluaties, aLd identification of carM tione of adequacy and inadegancies of specific evt Wation criteria la supp. L Fellowing is a discussion of the issees:
In my Seabrook salt interview, Nr. Vickers requested that sealer sembreak Manageoest resolve the stafflag inadequacy isome (A.4) by recrafting more staff. sembrook's Management asked if they could rely upon the Consonwealth J
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8 of Massachusetts to. provide second shifts of personnel for those posittene which Seabrook had only identified one shift. Mr. Vickers answered *Yes."
corrected his answer-with my answer "No " P1 see note I had to override the NRC Senior Nesber as well and inform them on the policy contained in Supp.1. -
I pointed out:
o that the current seabrook Utility Offsite Plan indicated that sufficient resources existed without State and/or local government resources:
o that the interpretation of " resources" in the soeuaption should be legal authority only. otherwise, under Part 1. Section 5 of Sup. 1, these I
resources would be identified and committed by participating State and local governments: and
.o that'supp. 1 required the Utility Offsite Plan to identify and cotalt,the resources necessary to implement the plan 1.e., the assumed resources of the State could not be considered "cosaitted."
l In discussing the issue of staff inadequacy (A.4) with Seabrook staff today, they raised the issue that FEMA had testified that evacuation related positions were only {
required for one shift (Mr. Flynn's testimony for seabrook, page 4443). I stated that I was not aware of this position and testimony, and my understanding and interpretation of evaluation criteria A.4 was that the offeite response organization aust be capable of continuous operations (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />):
1.e., a ainlaus of two ahlfts
-(maximum of it hours per shift) for all positions identified in the Utility Offsite plan. I pointed out that from the start of an energency (defined as an Alert), the specific time intervals (contained in Table 3 of NUR50-0684-FEMA / REP-1, Rev.1) range from 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to 1 day (34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />) before the start of atmospheric release, thereby, substantiating the requirement for continuous operations (34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />):
1.e., ao one cauld be in'a pos'ition to forecast when protective actions would be requirsd:
therefore, one had to be in the position to implement protective actions en a 34-hour basis. Note. I believe that some positions would not be required after certain protective actions have been impletected: e.g., after,an evacuation, the staffirg of traff$c management points'would est be required, but the staffing of access control points would be.
$nconclusion,IasrequestingthatFEMAHeadquartereprovidesethefollowing:
clerlfigation and/or correctfdn,:
1.
Did FEMA's Office of General Counsel state that certSin evacuation ralated posittens had to be suffed only for one 18-hour shift?
8.
If so, is this position the Agency's position?
I 3.
mat positions can be desigasted for one shift only (assuming this is the Agency's positica)?
4.
If act, what is the Agency's positica regarding 84-hour contianoes operations? Objective No. 84 of St RE-8 states 'Desenstrate the ability to malatain staffing on a coattamoue 34-hear basis by actual shift change.' This implied that offsite response organisationa aset demonstrate an actual shift change for 'all designated positions.'
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clarification on the assumption of Supo.
- 1. (The interpretation of the resources of non-participating State and local governments.)
1.
If the interpretation of " state and local government's resources where response la necessary" le " legal authority." then so infore se and take
.the steps to brist FEMA Region !! staff, 2.
If the interpretation of " state and local government's resources ubers s
response is necessary" is " legal authority, personnel, equipeent.-and
' facilities," then ! request that you amend supp.1.
This interpretation I
will be in conflict.with part 1, section B, that states the Utility I
offsite Plan shall identify and consit the resources identified by the utility and participating State and local governments.
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Establish a FEMA nosition on adeauate staffins.
(If two shifts are required,I should the designation of the number of staff by position be 2004,380s,etc..!
per shift?
1 i
For example, if a Plan designates 10 persons for a position per shift, then one would require a sinisua of to people to be identified, trained, and qualified to respond 'in order to say that adequate staff has' been cannitted.
Mowever, at any given time during the year it would be doubtful that all 80 persons would be available (e.g., some pers,ons would be in travel status, vacation' status, elck, etc.).
I note that FEMA's internal guidance (FINA Manual 4720.1) specifies that 4004 designation per position by shift be 3
identified.
Using the above example, 40 persons would be designated, trained j
and qualified for assignment to the 10 person / position designation by shift.
-Since the Seabrook organization is requesting technical assistance and a alte visit from se next week, I would appreciate your response on the above two feeues o
as soon as poselble.
If you hava any questions, please call me.
cc. Dr. Joan Rock, SL-NT-TM
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M. Sanders, SL-NT-TM l
C. Wingo. SL-MT-TM 1
Wm. Cusaing 000 j
J. Flynn, 00C 1
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i" FEMA REGION X
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FACSIMILE a_ : n TRANSMITTAL Date:
l FROM TO
==acs wM' Washington, D.C.
DATE.Tl DIE = CROUP XATION _ Bothell WA LOCATIONr Nt. Ri c h a rd 11, Genovan NAMEt "9-GC-PL TICE SYMBOL _rH/DEP CFTICE S EBCLI FT5 646-4103 TO P
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HPMotiE EXT FIS 390 4693 TELEPHONE EXT:
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pecial instructions, Faz Identification, Suspense, E'IC.)
Typed Name of Rolesse
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'ransmittal & Return Original direct to Richard W. Donovan Richard 4. Donovan in,", with date and time indicated.
RED Program Officer R eM No. to be used:
Automatic: 202-646-2531 Con firma ticti:
202-646-2530 or 2533 ErLEASER'S INITIALS :
PREPARATION INSTRfITIONS
- 1. cesplete all information with the eseeption of dete-time-group.
- 2. When sending material to FD') Hesdguerters, 1.ndicate in REMARX5, the telephone number to be used, if known. Provida both the number to cell to the addressees facsimile machi 3e and if it is en sutomatic machine, we **ill need a number to cell to verify receipt of transmission.
- 3. Authorized relessers: Besionsi Director, Division Directors, cernunications chief, i
and professional staff in the Office of the Regional Director.
FIMA RX Tom RX-Ch (07/83)
(Previous editions are obsoleu end should not be used)
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