ML20247G970

Intervenor Exhibit I-MAG-93,consisting of Forwarding Guidelines for Regions to Use in Implementing NUREG-0654/FEMA-REP-1,Rev 1,Suppl 1

ML20247G970
Person / Time
Site:	Seabrook
Issue date:	05/17/1989
From:	Gordon Peterson Federal Emergency Management Agency
To:	Federal Emergency Management Agency
References
OL-I-MAG-093, OL-I-MAG-93, NUDOCS 8905310126
Download: ML20247G970 (6)

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Washington, D.C. 20472 '89 NAY 23 P6 M OFFIC) w e 1;,,. <

DOCKE % U 4 a nect Q' 7 1988 MEMORANDUM FOR:

Regional Directors Acting Regional Director FROM:

Grant C. Peterson Associate :irector 4

State and Local Programs and Support

SUBJECT:

Guidelines for Regions to Use In Implementing NUREG-0654/ FEMA-REP-1, Rev.1, Suppl ement 1 With Qualifying Exercises The attached guidelines are provided for comment and interim use in preparing for and evaluating qualifying exercises where State and/or local governments decline to participate in emergency planning and exercises. They are in the fom of an Amendment to Guidance Memorandum EX-3, issued February 26, 1988.

This guidance should be used in conjunction with NUREG-0654/ FEMA-REP-1, Revision 1 Supplement 1.

The existing modular format should continue to be used in conjunction with the evaluation criteria of Supplement I until the modular format is revised by Headquarters to incorporate the use of Supplement 1 and this amendment.

This guidance has been developed jointly with Nuclear Regulatory Commission staf f and has been approved by Mr. Thomas E. Murley, Director, Of fice of Nuclear Reactor Regulation.

Comments should be provided to FEMA Headquarters, attention Technological Hazards Division, by March 31, 1988. Any questions concerning this matter should be addressed to Vern Wingert at 646-2872.

Attachment Thomas E. Murley, Director, Of fice of Nuclear Reactor Regulation, cc:

Nuclear Regulatory Commission 8905310126 890517 PDR ADOCK 05000443 Q

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i Washington, D.C. 20472 MAR 7M Attachment Guidance Memorandum (GM) EX-3 Amendment Purpose 1.

This document amends the guidance in GM EX-3 to accomodate the testing of utility offsite plans in qualifying exercises.

This amendment addresses the application of exercise objectives of GM EX-3 to exercises in which State and/or local governments decline to participate with the utility.

It also specifically delineates what constitutes an adequate demonstration of those exercise objectives pertaining to functions for which utilities are dependent upon State and/or local governments for legal authority to carry out their emergency responsibilities.

2.

This amendment will assist evaluators in determining the knowledge and Capability of the utility offsite response organization personnel to advise and assist State and local of ficials in implementing those portions of tne offsite plan where State and local response is id enti fi ed.

3.

This amendment is intended to facilitate the implementation of the Nuclear Regulatory Commission (NRC) regulation,10 CFR Part 50.47(c)(1) and 10 CFR Part 50, Appendix E, Section IV.F., dated November 3, 1987, (52 FR-42078) and the planning standards and evaluation criteria in NUREG-0654/ FEMA-REP-1, Revision 1, Supplement 1.*

Guidance l

1.

The nature of the qualifying exercise is stated in 10 CFR 50, App.E.IV.

F.(1):

"A full participation exercise which tests as much of the licensee, State and local emergency plans as is reasonably achievable without' mandatory public participation shall be conducted for each site I

at which a power reactor is located for which the first operating l

license for that site is issued after July 13, 1982.

This exercise shall be conducted within two years before the issuance of the first t

operating license for full power (one authorizing operation above 5%

of rated power) of the first reactor, and shall include participation by each State and local government within the plume exposure pathway i

EPZ and each State within the ingestion exposure pathway EPZ..."

2.

The amended NRC regulation in 10 CFR Part 50, Apperdix E,Section IV.F.6.

-provides tnat:

"The participation of State and local governments in

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an emergency planning exercise is not required to tne extent that the

• The guidance herein may be amended as the law develops and requirements or the evaluation criteria are changed or modified.

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2 applicant has identified those goverments as refusing to participate e

further in C gency planning activities pursuant to 10 CFR 50.47(c)(1).

In such ie :3, in exercise shall be held with the applicant or licensee and such aover vntal entities as elect to participate in the emergency 1

m planning orceu.

- All~ qualifa.og exercises should have ingestion pathway demonstration including the activation and operation of emergency operation facilities, field team functions (e.g., sampling and laboratory analysis) and the dissemination of agriculturally-related information and instructions.

It may be necessary to have a separate scenario to drive sufficient ingestion pathway exercise play.

"The offsite response organization shall attempt to involve the non-participating State and local-government in the exercises and drills, but their participation is not required." (Supplement 1, ev61uation criterion N.6.).

This provision also applies to ingestion-only

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. exposure' pathway states.

3.

Since the purpose of this qu'alifying exercise is to test as much of the emergency plans and. preparedness as is reasonably achievable, without State and/or local. participation, under Supplement 1, the utility snould demonstrate a total of 36 exerc! e objectives.

This consists of 35 of the 36 existing exercise objectives in GM EX-3, plus an additional objective that incorporates evaluation criteria of Supplement

.1.

- Objective 36, unannounced and off-hours exercises and drills, does not apply to a qualifying exercise.

- While implementation guidance in GM EX-3 permits State and local governments to delay demonstration of exercise objective 9 until l

calender year 1989, it is ~necessary for utility offsite response organizations to test this objective for qualifying exercises held in calender year 1988.

Objective 9 states, " Demonstrate the ability to obtain samples of particulate activity in the air-borne plume and promptly perfonn laboratory analyses." (I.10.)

- The following is a new exercise objective that parallels the Supplement 1 guidance. This objective is as follows: " Demonstrate j

the capability of utility offsite response organization personnel to interface with non-participating State and local governments through their mobilization and provision of advice and assistance."

(N.1. b., E. 6. and C. 5. )

4 The following is a subset of the 36 exercise objectives in GM EX-3 that may be legal authority-sensitive and which shou' d be demonstrated in cualifyino exercises. -They may b.e authority-sens tive because some-Espect of their implementation in an actual radiological emergency L

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and local governments. '" r t"" d: :n t = ie. ef u n e vascu wi

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in an exercise could be deoendent unnn how authority-related issues are addressed in the utility offsite response organization olan, pee item b Delow. ) Depending upon the provisions of the plan, demonstration of these objectives might be ' limited to the offsite response organization providing advice and assistance to controllers and evaluators who will afford appropriate opportunities for the players to demonstrate their knowledge and interface capabilities.

Objective 11. Plume Protective Action Decisionmaking (J.10.m.);

a.

b.

Obj ectives 12, 13, 14 and 15.

Alert, Noti fication and Emergency.

In fonnation (E.5., E.6. and J.10.c.);

Objectives 16,17. Use of KI (J.10.e.f. );

c.

d.

Objectives 18,19. Implementation of Protect' ' Actions (J.9.,

J.10.d.g.);

e.

Objective 20. Traf fic Control (J.10.J.k.);-

f.-

Objectives 21, 22.

Registration, Monitoring, Decontamination and Congregate Care (J.10.h., J.12.);

i. Objectives 23, 24. Medical Services (Transportation and Facilities)

(L.1,L.4.);

j. Objective 25. Decontamination (K.S.a.b.);

k. Objective 25. Supplementary Assistance (Federal /0ther) (C.1.a.b.);

1. 0bjective 30. Ingestion Exposure Pathway (J.9., J.11) and

m. Objectives 32, 33. Recovery, Reentry and Relocation (M.I.).

5. The scope of the demonstration of the exercise objectives should include emergency personnel, facilities and resources required by the scenario and exercise play, keeping in mind that the purpose of the qualifying exercise is.to test as much of the emergency plans and preparedness as is reasonably achievable, without State and/or i

local participation.

The dearee of demonstration of individual _

exercise objectives should test the workability of that aspect of the

% For example, it will be only necessary to activate those relocation centers that are dictated by the scenario and exercise play and, therefore, not necessarily all other relocation centers.

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6. The demonstration and evaluation of the objectives should follow l

. the specific provisions of-the plan. being tested. For example,

'l the activation and deployment of utility offsite response organization 3

personnel should.be performed at the emergency classification level l:

! designated in the plan.

If the plan requires the' utility offsite l'

response organization to secure legal authcrity to carry out necessary functions,' they should follow the procedures contained in L

the plan that would be used in the event of an emergency.

Actions in li an exercise! simulating the' securing of appropriate legal authority l..

may include the following: A simulation of the general deputization of utility offsite response organization personnel', a simulation of the ad hoc securing of authority on a case-by-case basis or a simulation of the direct assumption of responsibility by State and local governments.

7. Consistent with the guidance in Supp.1, evaluation criteria N.1.b.,-

"An exercise shall inclun mobilization of offsite response organiza-tion resources adequate to verify the capability to respond to an accident scenario requiring response.

This. includes the demonstration of offsite response organization capabilities to interface with non '

participating State and' local government, but does not include the use of stand-ins for the anticipated State and local response "

8. FEMA will evaluate the ti.neliness, completeness and effectiveness of interfaces between utility offsite response organization personnel. through interactive communications and exchanges with controllers and evaluators. While the ' controllers will not function as. 5,tand-ins,.they will provide appropriate opportunities for the players to' demonstrate the. knowledge and interface capabil; ties of. utility offsite response organization personnel.

The utility of fsite response organization personnel i.n. facilities will be expected to make telephone calls and' forward information to control cells.

For utility offsite. response organization personnel in the field, evaluators will use directed questions to. determine their ability to carry out their interface capabilities.

Thus, FEMA' will use information secured by both exercise controllers ard evaluators to assess the utility offsite response organization's interface and liaison capabilities.

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9. This guidance has been jointly developed by the Nuclear Regulatory Commission (NRC) and the Federal Emergency Management Agency staff and has been approved by the Director of the NRC Vf fice of Nuclear Reactor Regulation.

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