ML22230A103
| ML22230A103 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1979 |
| From: | NRC/OCM |
| To: | |
| References | |
| Tran-M790913 | |
| Download: ML22230A103 (79) | |
Text
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NUCLEAR REGULATORY COMMJSSION IN THE MATTER OF:
PUBLIC MEETING BRIEFING ON SECY-79-499 -
REPORT OF TASK FORCE ON EMERGENCY PLANNING Place -Washington, D. C.
Date _ Thursday, 13 September 1979 ACE - FEDERAL REPORTERS, INC.
Official Reporten 444 North Capitol Street
- Washington, D.C. 20001 NATIONWIDE COVERAGE.- DAILY Pages 1 -
77 Telephone:
(202) 347-3700
r CR7036 1
DTSCLAI}1ER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on Thursday, 13 Seotember 1979 in the Cornmissions 1 s offices at 1717 H Street, N. w., Washington, D. C.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is in.tended solely for general informational purposes.
As prov-ided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or argument contained herein, except as the Commission may aub"-iorize..
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25 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION PUBLIC MEETING 2
BRIEFING ON SECY-79-499 -
REPORT OF TASK FORCE ON EMERGENCY PLANNING Room 1130 1717 H Street, N. W.
Washington, D. C.
Thursday, 13 September 1979 The Commission met, pursuant to notice, at 3:35 p.m.
BEFORE:
DR. JOSEPH M. HENDRIE, Chairman VICTOR GILINSKY, Commissioner PETER A. BRADFORD, Commissioner JOHN F. AHEARNE, Commissioner PRESENT:*
Messrs. Carter, Gossick, Bickwit, Chilk, Kenneke, and Engelhardt.
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PROCEEDINGS (3:35 p.m.)
COMMI::3SIONER GILINSKY:
We are to hear a report 4
from the tasK force on emergency planning.
Mr. Carter, I 5
guess, is speaking.
o Lee, will you introduce him?
7 MR. OlSSICK:
Thank you, Commissioner Gilinsky.
d You recall we were here on June 28th on a status report by 9
the task force that was established in June to undertake the 10 review of our emergency planning activities and to come up
.11 with recommendations on those things which we felt necessary 12 to improve the overall effort.
13 The task force reported in on August 9th, and that 14 report was sent to you by SECY 79-499 on August 21.
We 15 tried to put a summary on top of it that might make it a 16 little easier to digest in a somewhat easier fashion.
l"m 17 not sure how successful r.hat was.
Id The way we're going to present this this 19 afternoon, we will ask several people addressing each of the 20 major parts of the overall planning effort, to come up and 21 give their part of the report in a very brief fashion.
It 22 might be useful if we handed out to you a tagged copy of the 23 paper here, which wi~l make the* enclosures much easier to 24 find *.
If you find that useful,. I am sure you may have made 25 notes on it, but perhaps you can use. this just to find what
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CO.\\Ai11ISSIONER AH!::ARNE:
Since you raise that, when will we be getting a summary of the public comments on the advanced MR
- GOS-SI CK :. I om?
MR. CARTER:
Mike is reviewing this and I think Mike's going to discuss this.
MR. GOSSICK:
We will be covering that, too, shortly.
One other matter having to do with the organizational management aspects of this and also mentioned in the memo that you sent us, Commissioner Ahearne, we will discuss that toward the end of this briefing.
recommendations on that aspect.
We have some I would like to. touch.just briefly on the* other questions that you asked and point ou-c that the various speakers, as we go through it, will address the questions that you have indicated here about what actions have I offered or have the audit or have the office directors ordered, and those that are pending Commission decision.
The major i terns, of course, I just mentioned.
But there are some other things; why, if or not those things would prejudge the rulemaking.
As to any substantial disagrEement, to the best of my knowledge, other than perhaps some difference of views on the best way to manage this effort, which we can address
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later, there are no minority opinions or disagreements.
In June when we were here, there was some discussion or debate a~out the modeling effor-c that was being proposed at that time, which has been set aside, really.
So that is no longer an issue.
So with that, I will ask Mr. Carter to introduce the briefing, and then proceed with that.
MR. CARTER:
Thank you, Mr. Gossick.
We have members that represented all the major offices here today.
In the front of the notebooks, we have a list --- and I have some extra copies, so maybe you can each work from these --- in the order in which they wi 11 be discussed.
First, I would like to summarize briefly how the task force approached this objective and its mission.
We had representatives from each office, each major program office within the staff, as members, and in some cases more than one representative from the offices.
We created, sep*arate from the task force itself, a working group of representatives from the Qffices involved.
That working group was headed up by Charlie South, who is also here today and can respond to questions.
They separate themselves from the task force while we were working on the Lssues that were be.ing developed for public comment, which the Commission used part of.
And they tried
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and I think did a very good job in developing a description of the current emergency planning system and critiquing the current emergency planning system, which led to a group of 30 problem areas which are identified very specifically in the Commission paper that came up.
Those issues or problem areas basically were presented to the task force.
The task force discussed them in detail, looked very hard at the wording for the problem areas, crying to really understand, interpret the wording chosen by the working group that supported the task force, trying to get an in-depth understanding of why those people chose these problem areas.
I think they were massaged very thoroughly.
Then the task force agreed UF=Qn the three problems and chose to approach the solution of those problems via a series of action plans, which are represented in the Commission paper.
Each outfit developed their action plan after we had agreed upon really a determination of which office should have a lead role, a support role, whether it was long-term, short-term, for each of the problem areas.
Then the action plans were developed.
The way wa would like to discuss the action plans today is go through the major offices as indicated on the agenda and summarize, as Mr~ Gossick indicated, the organization action plan, which really comes first in the
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Commission paper.
~e would pr~fer to discuss it last
- So. with that, if Brian Grimes will discuss the NF~ R act ion pl an
- C01v\\NUSSIONER AHEARt{E:
Just to help those of us who might have read the paper firs~, is there going to be any comparison in the way the briefings are conducted-~hd the way the paper is laid out?
Mi?. CARTER:
r'le are following the paper in order, basically, except for the organization COMMISSIONER AHEARNE:
Fine.
But for example, when you go down the problem, you'll be using the description of the problems and the solutions as indicated in the pa per?
MR. CARTER:
Because of the limited time, we have not proposed to address each of the problems.
Each office was going to highlight one or two problem areas that they thought were important, then, of course, respond to questions on specific problem areas.
COMMISSIONER AHEARNE:
Fine.
MR. GRIMES:
With respect to the NRR effort -
and I think we have had fairly thorough discussion last week on the team approach, to try to promptly upgrade the state of emergency preparedness at operating reactor facilities, and I won~t go through them and beat that again.
We are making progress.
The f.irst two site
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visits are next week, followed the following week by some more site visits on the firs~ plants being reviewed by the six teams.
And we are developing guidance on action level criteria, which we will provide to the Commission in the next few days for their information and possible comment.
With respect to the problem areas, most of the areas are being addressed in the context of the ~earns, and the one area where we have not yet put significant resources is on -- I don't remember the numbers.
It is F-2, which is the last one, which is developing crtteria for joint exercises, to be working with state programs.
But our efforts to date have been getting the teams out, getting the emergency response plans reviewed, as opposed to focusing on the test exercises at this point.
But all other areas are under way to some degree.
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9 COMMISSIONER AHEARNE: If we could go back to
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problem area 6.
Could you comment why it wasn"t appropriate for the NRR a_ction plan to specifically address that?
MR. GRIMES: The,problem here that the licensee-"s risponsibility for emergency planning exceeds his direct authority to affect the actions of off-site officials is a r9cognized problem.
But we did not believe that we had the 8
.resources~ or really, that it was very realistic to expect 9
to change the relationship between the federal and state 10 government and private industry in this regard.
11 And we --had to recognize that as a problem,. recognize 12 that our authority is over*the licensee, and.work thro~gh 13 that mechanism.
14 COMMISSIONER AHEARNE: When you say it. wouldn-"t'be 15 realistic to change it 16 MR. GRIMES: Well 17
_COMMISS TONER AHEARNE: Let-" s put the question whether 18 or not it would be realistic aside just for a minute.
What' 19 kind of changes ~ould you think would be significant 20 improvement?
21 (At 3:35*,, Chairman Hendrie entered the room.)
22 MR. GRIMES: Well, to solve thi.s. problem, one would 23 have to give.- to P!!t in_ affect restrictions or penalties 24 25 on o.ff-si te agenc,ie$ to iri some* way compel them to do certain thirigs.* **r don't think.it's realistic to do that. I
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- don1 t have any particular ways of approaching it.
2 MR. GOSS ICK: Brian, this is really one of the 3
aspects of the rule-making that we're in for the legislation 4
that may come about.
You're saying that you can~t go ahead
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with it and act in advance of whatever is-decided on
.6 rule-making, or whatever legislation finally is produced.
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. 14 15 16 I 7 18 19 20 21 22 23 24 25 MR. GRIMES:.That's correct. And further, I don.Jt really see a good way to do it, thinking *about it myself.
MR. GOSSICK: That's one of the questions._*
Commissioner Ahearne of the kind that yo~ ~sk, __ that would pre-judge, I think, the rule-making-~:- **:);~:*tt;;;
COMMISSIONER AHEARNE: Well, there could have been
\\ a more detailed descriptidn of what the problems were.
--MR. GOSSICK: Well, this is a very_brief summary/
of that.
COMMISSIONER AHEARNEi But this particular sentence wasn 1 t ev~n considered.
So I imagine that that's as lengthy a summary as there probably is *.
Go back, then, to page 11Cf)C2>~
Do you have an
~stimat~ of wh~n those Joint exercise criteria might*be developed?
MR. GRIMES: No.
I think it's a task that we have to. face {n the next_ two 6r three months *. Right now we have nQt put any re sources on that.
- COMMISSIONER AHEARNEz Once resources are put on i.t,
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- 2 you think then it would be a 2-to 3-month job?
- MR. GRIMES: Yes.
3 COMMISSIONER AHEARNE: All right.
1 I 4
MR. GOSSI CK: Any other questions for Brian before 5
we go on to NMSS action plan?
6 COMMISSIONER* AHEARNE: I imagine whe[l you get back to the organizational question --
8 MR. GOSSICK: Yes, certainly.
9 MR. CARTER: I would like to briefly summarize then 10 and make some points on the NM.SS action plan.
11 One-of the first impacts of Three Mile Island NMSS 12 I believe was it forced them to take a very hard look at 13 emergency planning within the fuel cycle facilities,.
and 14 15 the* realization very rapidly that we had* not been doing, really the job we need to.do on fuel cycle perspective for 16 emergency planning.
Ii Tha_regulations require emergency plans for Part 18 70 licensees, part 6f Part 70 licensees, fuel processing, 19
. fuel.fabrication/-- you have*six conversion plants 20 and the reproce,ssing facilities such as:_ NFS.. West.
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Valley.
22 There, is no specific requirement unde_r Part 3 of 23 by-product material licensees: to have emergency plans.
- 24 25 Now Squibb, for example~ has a voluntary emergency plan, which is a very good plan, - we feel.
What we would like to do,
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12 and what -we have started to do, is to perform detailed accident analyses for all of our facilities to determine 3
loo~ing at the criticality, fire, explosion, natural
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phenomenon, abuse ~ccidents,. coupled with the actual location
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sometimes in urban areas ~f facilities,.what a priority list 6
would be in developing emergency planning for these 7
facilities.
8 COMMISSIONER GILINSKY: Presumably, the accidents 9
that you analyzed are in the safety analysis reports, aren1 t 10 they?
MR. CARTER:. That.1s. correct~
We feel, as indicated 12 in our problem area. B-3, which is on page 10 of the NMSS 13 action plan, that the licensee plan really was based on 14 15
- accidents up to and including the most* serious design basis accident, which in some cases probably, considering Three 16 Mili Island, it is not a serious enough accident to do 1,
your planning.
18 COMMISSIONER GILINSKY: Is that the point then?
1~
You're thinking of it in terms of supplementing the discussion 20 of accidents that,are being considered?
21 MR. CARTER1 Yes, sir.
Going a.step further, 22 looking at the* human *e_rror of possibility, multiple equipment 23 f al.lures, whatever we have to look at to see how serious 24 acc:ident* situations could-develop* in these plants.
And that-' s 25 what we're thinking about.
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- 18 19 20 21 22' 23 24 25 13 We have some effort underway under 8-3, as summarized there.
We are just getting started. We're trying to take a look, as*we had dis*cussed in the budget presentations also.
(At 3:50, Commissioner Bradford leaves the room.)
MR. CARTER: Another problem area identified in the NMS.S area which is E-3, which is on page 16, we felt that the task fore& and th~ working group felt that the majority of operating faciiities had not been evaluated against the staff's current criteria for emergency planning.
We certainly had to agree with that because the requirements for Part 30,
- by-product facilities, did not even exist for emergency plans.
We wanted to.take a hard look at that.
After we had gone through these analyses, we want to really come up with* pre-con~eived framework of*a criteria, the staff guidelines, the regulations to be strengthened if nec~ssary, and the guidance to the licensees, really defining the functions and their responsibilities,. of all the participants, the licensors, the licensees, what we would expect from local and state governments surrounding the facilities, how that would go. into or impact the state and local government pl ans_ around,the facilities.
We, 'recognize the need to expand the regulations in the area of' the' fuel cycles to cover the other licensees
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14 covered now.
We're not sure to what extent we do believe they need to be -- the regs need to.be strengthened in Part JQ.
3 and 50, as they apply specifically to the fuel cycle 4
facilities i*n lieu of Just the reactor language presently
- i there.
5 We have those*efforts underway and*we will be 7
coming to the commission in the near future.
We have proposed 8
an action plan to present to, the commission proposed 9
by the end of this year, proposed language changes in Part 30 JO and, if necessary, Part 40.
11 That's basically a summary of our approach.
12
- COMMISSIONER AHEARNE: You list in Problem F-2 a J3 second review.
14 MR. CARTER& F-2 being evaluation criteria for 15 drills and exercises are not defined?
16 COMMISSIONER AHEARNE: Yes.
l 7 MR. CARTER: Yes.
We would like to reassess the 18 criteria. in the.procedures* for fuel cycle facilities.
19 COMMISSIONER AHEARNE: Now that, you estimate, is 20 a short-term completion term?
21 MR. CARTERr Our priorities now are to do the 22 detailed accident analyses to put a priority ranking, as you
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~.might say, against the facili.ties *.
- Take a look at the 24
- 25 changes to Part 30 for.the by-product licenses. As part of that guidanc.e dev.eclopment or thinking of the guidance there
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9 10 J I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 we would have to look at that criteria.
I would estimate it would be the first half of next year.
Jim Sniezek can discuss the I&E action plan.
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4 l 6 MR. SNIEZEK: I will highlight the I&E actions that I think are of special interest to the commission.
The I&E action pian, the first item is on page 5.
One of the problems identified was that terminal arrangements between the agencies need approval.
6 They were specifically by IRAP. The meeting with DOE and other agencies,* members of IRAP,was'- yesterday.
8 And it was their outline, what basically the problems 9
are with IRAP, what can be improved. And what we are 10~
pushing for is more and ~learer delineation of who is in I
11 charge, responsibility, a commitment of resources and not 12
. a voluntary assignementpf resources.
13 That. agency in *charge really call*.on resources of 14 IS another agency..
N<lv' FEMA representatives. were there and they want 16 to fold us under the FEMA concept and give it more 17 statutory authority.
18 The next meeting is scheduled -- well, by November 19 I st, we're to have comments specifically on IRAP, the 20
- specifies that we would: like to be changed, in -writing. All the
~--~ --.... *****-*-- --*****-
21 agencies are to come-in for comments and then. shortly after 22 that,* there. will be another meeting *to discuss where IRAP 23
- will go from there.
24 25 But we believe the* basic IRAP framework. is good,, but it needs* some* hardening as* far* as responsibilit*ies,. who"s in
036.09.2 I ;;.h W.1 17 charge of specific actions.
2 The ne*xt item which can be found on pages 7 and 8, 3
it's basically that th~ instant response program needs 4
revision.
That would come out on B-2.
- COMMISSIONER GILINSKY: Let. me understand *. Would 6
.* I RAP encompass all federal efforts?
MR. SNIEZEK: No.
It would come under the FEMA 8
umbrella.
But it is really the resources that are available 9
by the agencies that would really respond to a nuclear 10 accident.
11 COMMISS !ONER GI LINSKY: When you say who is in 12
- char-ge of the accident *--
13 MR. SNIEZEK: In other words, if itJs an NRC license 14 15 facility, who should be.calling the shots at the scene? It*
should probably be the NRC, as far as the coordination of 16
- the -effort.
If it's a DOE facility, DOE would be.calling the l'i shots as to w_hat should-. be done. If it happened to occur in 18 an agr.eement state and we. were -providing support to the 19 agreement state, they would be calling the shots of how they 20
- thought the resources should be deployed, what measurements.:.snould 21 be taken, et cetera.,. so everyone wouldrrt be going helter 22
- skelter doing the:i:.~i-JW-n,;. thing. - There would.. be better 23
- coordination of the overall monitoring of. the.. accident.
24 25
- COMMISSIONER.'.GILINSKY:
- Are you speaking just of monit:oring or of* othe*r things, too?
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18 Are there instructions or*recommendations that
- would be giveh to the licensee in the facility?
MR. SNIEZEK: That would be tied in.
But the details of how they would go, weJre not there yet.
CHAIRMAN HENDRIEa But under the overall radiological 6
emergency plan, the federal plan, it would go a lot further l
- than just moni taring.
a*
MR. SNIEZEK: That's correct.
9 CHAIRMAN HENDRIE1 And it would go outside the things 10 that the IRAP plan covers, for instance.
And it would 11 include deployment --. such things as deployment, emergency 12 field kitchens, medical equipment, cots -
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!RAP.
MR. SNIEZEK: Right.
That would be outside of CHAIRMAN HENDRIE: Part of the federal disaster 16 assistance kind of action *.
And there are some interesting 1,
questions, then. If we should ever have a Three Mile Island 18 sort of situation, I expect whoever is our senior officer at 19 the site_ wilL not want to have to worry about how people 20 are taken care of in terms of provision for people who are 21 evacuated, or something like that.
22 You will want to' be* able to call for an evacuation 23 is one ls* nece:.5sary and_ trust. that there *be* an appropriate 24*
25 organization out th:ere1.-to take careio-f it as it moves on out.
MR *. -SNTEZEK1: IRAP.is not getting into that. type. of
036. 09.4 19 discussion.
2 COMMISS !ONER GI-LINSKY:. Isn1 t that the responsibility
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of the state?:
4 CHAIRMAN HENDRIE: Yes, I think it is. But there is
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substantial federal aid that turns up.
Remember, there were 6
people from what is it, the Federal Disaster Assistance 7
Administrati-0n down there in the Governor1 s -- right outside 8
the Governor's door.. And they deployed a lot of material and
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people, in fact, in preparation.
And weJre waiting for 10 whatever the st~te~called to~.
11
~ Well, I can see some complicated discuss!,ons and 12 trying to sort out who does what, but obviously, better before 13 than after.
14 COMMISSIONER AHEARNE: Clearly,.there will be a*
15 lot of discussions on that., both in among them or different 16 places.
I would guess that we still have a long way to 1,
go until we see clearly who is going to be in charge of 18 what.
19 MR. SNIEZEK: It's my understanding that FEMA wants 20 to fold IRAP into a small part of the overall.umbrella of 21
- response *
. 22 CHAIRMAN HENDRIE: Well, they n.eed to prepare -
they 23
- are under a. mandate to prepare a national plan and they have 24 25 got*to either-replace-or refurbish that thing which serves.as the overall federal planning document which has the acronym,
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3 20 FRPPNE.
I guess l'm unable to help the Reporter with the spelling.
COMMISS !ONER AHEARNE: It's F-R-P-P-N-E.
CHAIRMAN HENDRIE:. Under two hours?
And IRAP would
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be a portion of that.
6 MR. SNIEZEK: On pages 7 and 8, there is a discussion 7
about the instant response program needs revisions *. That's 8
a few of the things that are happening right now.
The 9
revised EMP procedures are being outlined for discussions. at 10 an EMP meeting the week of September 17.
And the first 11 dedicated phone lines have been installed in the operational 12 center*going to operating power reactors and selected. fuel 13 facilities.
14 15 16 1 i The second 1 ine is.scheduled to be installed by the.
end of this year.
On pages I I and 12 --
COMMISSIONER AHEARNE: Jim, could i ask you a 18 question? You mentioned that there is developing rule-making 19 to determine who pays for the COlJUllunications at the licens.ee 20 sites.
Is that really a major issue?
21 MR *. SNIEZEK*- I don"t be:lieve.that is.
I don"t 22 think that anything has been started on it.
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.. COMMISSI.ONER AHEARNEt Does it really have to go through ruie~making _to* decide?
25 MR. SNIEZEK*. l'm. really not sure if it does.
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4 21, MR., ENGELHARDT: I am unfamiliar with that particular r eco rnmendat ion.
MR. SNIEZEK: It's one of the things that's going to be l coked at in the overall sequence,* whether it should or not. 'tie really haven-'t gotten to that area yet.
6 COMMISSIONER AHEARNE: You passed by an item on I
let's see, page 6 *. And i t.,s, I guess, with reference to 8
problem A-5., It's a report on the NRC role. NRC has not 9
adequately defined its role in emergency response.
10 MR. SNIEZEK: What we*'re looking at are things other II than the commission.role in emergency response there.
And
.12 there was a first.meeting of inter-office work group to 13 define what should we be, doing and *they come up with a 14 15 16 definition of what we should really do in response to an incident.
COMM! SSIONER AHEARNE: I guess from my own point of 11 View, I guess I think June, 1 980 is a *little late.
I would 18 guess that if we don't h~ve a fairly clear picture by the 19 end of the next few months in what ought to be our role, we 20 will have a number of people answering for us.
21 I guess I would like to know from* the staff what 22 they think, certainly by the end of the year.
June, 1980 is,_
23
-... MR. SNIEZEK: I bel:ieve by the end of the year we 24 '
will, have. 8' direction 'we'*re going' as far as teams or things 25 * *. of that, nature and how we will respond.*
rG36.09. 7 2
22 COMMISSIONER AHEARNE: I guess my point was I think the NRC~ as a body, is going to have to have a clear picture 3
on what its role is in emergency response.
And that is going 4
to have to be reached at least in the midst of the
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rule-making, and certainly by preparation of testimony in the 6
early spring.
And I Just don't think June, 1980 is going to 3
hack it.
9 MR. G0SSICK: The.first step on that problem, 10 Commissioner.Ahearne, is a lLttle bit involved in this meeting JI that Jim mentioned next week... _
12 I. asked Denton and Bill Dircks and Vic Stello to 13 get pulled together based on our experience of Thr.ee Mile 14 Island.
Assume another one like that or something of a 15 similar nature happened tomorrow *. What would we do as the.
16 EM~?
17 Eirst of all, let's assume that itJs the middle of 18
. the night and the commissioners are all out of.reach, for 19 whatever reason or another, or even if they are -
but at 20 least we're not getting into this other question that we got 21 into of the commission.-
22 But what is it that we would do* differently in 23 addit.ion. to, instead. of*, iri this case from that which we
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did i.n Thr.ee*: Mi.le... Is*! and?
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. It's *a.kind of an i.nteri.m, if you will, checklist
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23 for the EMP as it meets in the event of another accident.
And this will be a first cut at that kind of question.
I think it's the kind of thing, however, that will take much further steps.
I thought that it was important that
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we have some thing like that ready and on hand.
5 COMMISSIONER GILINSKYz Where* is the f.irst cut?
7 MR. GOSSICK: That's what we-'re meeting on. I think 8
it's Wednesday instead of next ~eek, to review a straw man 9
'that's being prepared by Vic and his people.
10 COMMISSIONER GILINSKY: And that is something that 11*
we Will have pretty soon?
12 MR. GOSSICK: Yes, as soon as we can look at it and 13 decid~.
This looks like it makes some sense.
And we will 14 1 :5 get,it down to you for your comments.
COMMISSIONER GILINSKY': Is this a very complicated 16 question?
1 1 MR. GOSSICK: I donJt think so.
I told Vic to keep 18 it short and simple because it's the kind of thing that people 1~
are going to hav~ to deal with, you know, in the midst of a 20 panic, if that ever happens.
And we don't want it to be a 21 long and complicated thing.
22 But they are examples of things that you know in 23 retrospect we would do it. dLfferen.tly *.
24 25 COMMISSIONER AHEARNE: Lee, I think the problem you may find-is-that,._ and I think* the steps. that you are taking
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24 are correct -- the point that Jim said he is starting on,-
it is:right.
It"s just that to then wait until June~
MR. GOSSICK: I agree with you. We can"t survivs just not having anything before June of JBO.
Whatever comes j
out of this may entail some further action that may take 6
longer.
7 MR. SNIEZEK: The short one was meant to define 8
really what had to be done.
The refinement comes later.
9 COMMISSIONER AHEARNE: And what I am saying is that 10 I think the l~ter ought to be no later than the end of 11 December.
12 COMMISSIONER GILINSKY: Or September.
I really don-Jt 13 sse it as all th~t complicated a question, unless I-'m really 14 15 missing something here.
MR. GOSSICK:* We-" 11 get to that this w.ee k and find 16 out why it"s so complicated or* what it is that they anticipate I J in addition to the kind of thing that I was talking about.
- 18 MR. SNIEZEK1 On pages 11 and 12, there is a 19 1 discussion of devoting additional licensing and inspection 20 resources to better implement emergency preparedness efforts 21 by the NRC *
.22 As *sri-an has inentioned,. the re are other teams,going* out.
23
!&E-has representation on* each of those teams.. In order to 24 25
- accomplish that,.. we have** defe"rred our normal routine inspection
. ' program in emergency prepared*ness and we believe that we can
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But as far as the recurring reviews of our emergency preparedness efforts, we do not have the resources to implement what we have laid out in the action plan.
As you know, we set forth these resources in our
'80 supplemental request and it was turned down.
ThereJs
-about 10 additional people in inspector positions that are necessary to accomplish what we had laid out in that action plan.
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2 26 Pages 12 ~nd 13, Problem E-4, to sharpen the incident notification criteria and expediting NRC internal 3
- notifications.
From the end of July, criteria was set to
- 4.
the licensees, power reactor licensees and the selected fuel 5
f ac il i ty l ic ens ees, the ones that have the hot lines 6
installed, which laid out sharper cfiteria by which they*
should report problems.
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 COMM! SS!C)NER GIL INS KY:
Does anyone ever ~se those?
Because as of a month or so ago, I remember asking and it had never been used.or used on one occasion.
MR. SNIEZEK:
The phone?
COMMISSIONER GI LINSKY:
Yes.
MR. SNIEZEK:
Oh, we get. several phone c~lls a week. coming in on the line_s.
If there-' s a reactor trip, they wi 11 normally call on that line, as an example,
- notification.
It's normally during the o ff-norrna l working hours.
Normally, during the daytime they make the normal calls to the regional offic3.
If. it happens at nigh_ttime, the call comes in to the response center.
At th~ sa~e time, in order to prevent delays in notifications during off-normal working hours, _all our regio.nal calls are. diverted directly to our headquar"ters operations center._
COMMISSIONER. AHEARNE:
As part of that, are you
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18 19 20 21 22 23 24 25 27 providing a set of clear instructions to the people at the other end of the telephone-line as to when they ought to use it?
MR. SN.I EZEK:
I don't know.
Let me check.. I don-' t. believe they have been written. yet, or it-' s in the plan.
Joe, is there a. clear set of instructions to the licensees*on when they should use*the hot line?
VOICE:
Only in the le.tter that we provide to the licensees for the criteria under which to use the phone.
Simply all they have to do is pick up.
COMMISSIONER AHEARNE:
No, my question wasn*'t if they knew*how to use the phone.
It is*when to use it.
The criteria that went out were a lLttla murky.
And my
- understanding was that_th~re w~s going to be an attempt to at least come out with a clearer set of criteria for the licensee.
_ VOICE:
I would say, based on our daily experience with the plants, we're essentially developing a dialogue with telephone operators, and they seem to be reporting many events whi.ch. are way below any threshold.
We haven't come up with any more specific criteria as to when in-fact they should pick up the telephone.
We-'re
- getting more information 1::haff we need.
COMMISSIONER 'AHEARNE:
I gue.ss when I read them
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28 my concern really wasn1 t that you might get more information than you -need, but it was' possible to be interpreted that 3
you would get less information than you might really want.
4 COMMISSIONER GILINSKY:
Of course, the main
- l purpose of these things was to make sure that there was a 6
link when either of the parties wanted to use it.
3
- 9 10 11 12 13 14
- 15 16 17 18 19 20 21 22 23 24 25 COMMISSIONER AHEARNE:
Yes.
In addition, though, that we would want to*make sure that they would use -it when we would want them to, and my concern was the instructions were still a li.ttle murky.
MR. SNIEZEI<s So far, we havenJt noticed *any real problem in not getting the information reported; that issue being reported to us.
Page 16, there is a discussion of need to improve the NRC monitoring capabilities under accident conditions.
And right now there i_s a task force that is working on defining the radiological monitoring improvement capabilities that we n..eed, and I expect a draft report from that *task force in November, and a final in December, in time to start ordering the equipment we think will be necessary during the next. fiscal year.
The TLD placement is* proceeding, placement of NRC TLDs around the sites..Le,tters were sent out to all state health department.s solic,iting' their c*ooperation *.. we have gotten responses,. I* be;l:ieve, back from all o.f them.
All but
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29 a few states. are very anxious to participate.
We expect to have TLDs around five sites in October of this year, and the
- remainder of the sites by the end of-this year.
COMMISSIONER AHEARNE:
Do I gather, then, from what you said that some states are not anxious to participate?
MR. SNIEZEK:
There are a few that are not overwhelmingly enthusiastic with resources involved and things of that nature.
Now,* the state role here -
we are* asking that they would place and collect the TLDs, send them to us for processing, and they would get a copy of all the reports.
COMMISSIONER AHEARNE:
Now, for those states that are not enthusiastic~ what do we. intend to do?
MR. SNIEZEK:
We'll do what we did in some of our other programs, that sometimes we go for a contract with a local high school science teacher, for example.
Or where we have a resident, _we may do it ourselves, if we can get a contract~
We intend to place the TLDs and collect them.
Now~ we would like to get the states to do it as a first priority.
Second priority,. to contract it out; and third priority, do it.. ourselves~
But we are going to do it.
.. Those, were the highlights that the Commission warited to hear *.
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-23 24-2S 30 COMMISSIONER AHEARNE:
Just as a question, on page J 1 of the front summary, assorted problems, under I&E tasks, down under C, you are going to procure operational parameters?
MR~ SNIEZEK*
Those are the data links for the operational parameters.
These are explanatory of the basic
- c.
C0MMISS TONER AHEARNE:
Yes.
MR. CARTER:
Mr~ Collins_will now discu~s the Office of State Programs action.
MR. COLLINS:
Mr. Chairman and Commissioners, what I thought I would like to do, since we only have a limited amount of time, is to use Enclosure 4, which deals with the office tasks, sorted out by problem, and try to give you at least a quick overview of these indi~idual problem task numbers and how they relate to the general responsibilities in the emergency preparedness area for the Office of State Programs *.
The first thing you will notice in there is that Items A~t,* A-2,- S:-4 and E-J in Enclosure 4 all in some manner* or another.relate to this FRPPNE that the Chairman refa.rred to,, the. Federal. Response Plan for Peacetime Nuclear -
. Emergencies._
Dr *. Hendrie had a meeting with Mr. Macy the other day concerning-the interrelationships betw.een NRC. and FEMA,
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- 22 23 24 25 31 and of* course we will be using the preliminary guidance that came out of that meeting between the two heads of the agencies to start looking into exactly what form this
~ederal Response Plan for Peatetime Nuclear Emergencies may turn into.
FEMA did indicate to us during that meeting that they intend to use the FRPPNE as a starting point and base for the national plan for radiological emergencies.
That's referred to in the Hart-legislation.
It also relates somewhat to the pending legislation in S. 562 that requires the NRC to develop an agency plan, and I think our thinking, at least in State Programs --- and I think this is probably shared by some other offices *- is that the development or the lead office role for.the development of the*agency plan probably should gravitate towards the Office of Inspection and Enforcement.
COMMISSIONER GILINSKY:
Say that again?
MR. COLLINS:
- The le ad off ice re sponsibi li ty in this agency for working on the agency. plan c..alled for by the Hart bill should probably gravitate to the Office of Inspection and Enforcement, since... they already do now manage the manual chapter which deals with this agency's response, and which would have to be added to and updated and
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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 So, since Inspection and Enforcement already really sits in the leadership role for the existing plan of the agency, such as it is, we feel it.,, s a. natural that they continue on with that work.
And since they hive already had some initial meetings with the Department of Energy concerning the IRAP and any pending provisions to the IRAP COMMISSIONER AHEARNE:
But to some. extent it depend,:5, doesn't it, Lee, on what resolution is reached on any reorganization?
MR. GOSSICK:
Right.
MR. COLLINS:
Yes, it would.
But I was talking about the way things are today.
The national plan that is referred*to, which relates somewhat to ~RPPNE, obviously, if the Hart legislation* goes through, will probably be a FEMA responsibility to develop plan for the nation.
Now, the FRPPNE is not a plan in itself *.
It.,s a guidance document, as Mr. Macy said the day before yesterday.
It is Just that the federal agencies, the 30-some odd federal agencies that helped put that thing together,. have Just not done* much with the guidance document to. turn* it into a feder~l plan.
Bu.bit will serve as the base for FEMA getting started on this*national plan *.
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CO MM ISSI ON ER GI LINSKY:
Does.F' EMA expect to devglop expertise in accidents --
MR. COLLINS:
Radiological?
COMMISSIONER GI LINSKY:
Yes.
33 MR. COLLINS:
They have some expertise now, Commissioner Gilinsky, but itJs mainly nuclear war-oriented.
Where their existing expertise comes from is the portion of FEMA that was the old Defense Civil.Preparedness Agency.
So there is some capability there.
COMMISSIONER AHEARNEi It"'s a reasonable amount as far as radiological measurement.
MR. COLLINS:
With respect to nuclear war.
COMMISSIONER AHEARNE:
It.,s still radiological measurement..
MR. COLLINS:
Right.
COMMISSIONER AHEARNE:
I donJ't want to leave the impression that the nuclear war aspects have anything to do with the strategic weapons per se.
It's.the effects that that agency was associated with.
MR. COLLINS:
Right.
Of course, many of the instruments that the old Defense Civil Preparedness Agency had, the radiological instruments which have been inherited by FEMA -
and there are millions of these.. instruments out there -
are, des.igned and constructed to respond to weapons-type.. fallout *.
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19 20 21 22 23 24 25 Now, some of those instruments are useful for off-site assessment of accidents which might happen at I
nuclear power stations, and right now we have a contract 34 with Idaho National Engineering Laboratory to look at the FEMA instruments to see which of them would be useful in assessing reactor accidents on site.
And we should have an answer out of Idaho perhaps in less than a year.
So those instruments would represent some additional capability out there.
It's just that no one has ever really looked very closely at the response of those instruments to the types of radionuclides which can come from a nuclear power station.
So that's Why we're doing that now.
The states have asked us to do this.
COMMISSIONER GILINSKY:
Somehow, this is all getting very complicated. FRPPNE and FEMA and IRAP --
CHAIRMAN HENDRIE:
The first thing you have to do is to learn the acronyms.
COMMISSIONER GILINSKY:
Doesn"t it come down to someone in the, Federal Government providing a place to state and other competent authority on whether or not people ought to get moved?
I can't imagine that being anyone else but the NRC.
COMMISSIONER AHEARNE:
I think it"s a little bit broader than that.
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obviously.
35 COMMISSIONER.GIL INS KY:
There are other aspects, COMMISS !ONER AHEARNE:
A lot of the advanced 4
planning, the coordination of the federal.agencies, the
. ~
state agencies,. the private. agencies, that in itself is a 6
fairly complicated operation.
1 MR. COLLINS:
The whole business of emerg9ncy a
preparedness is not just, you know, getting p~ople out of an 9
area.
It encompasses a lot of complex areas, one of the 10 l I 12 13 14 most complex of which is accident assessment, and a great deal of work has to be done in the area of*accident assessment.
And that's one of the reasons why we-'re taking I
a look at existing instruments that* are.already out in the
.hands of state and local people, that might be able to 15 provide them some useful information in the event of an 16 accident, again.
17 But *this has all got to be looked at.
The 18
- instruments have to be looked at and the response to the 19 instrume.nts has to* be examined.
20 COMMISSIONER,GILINSKY:
When all* is said and done, 21 after these assessments, isn't it a question of whether or 22.
- not persons* have to be moved or should be moved,* should move 23 out of the way or not?.
24 25 MR *. COLL.INS: *Well,- you: have* to make a decision whether you wan.t' to, mover. them or shelter them.
Under some
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. situations you may not be able to move them, and the protective measure that you might have to opt for is sheltering.
In inclement weather, that's aoout all you have got, really.* You wouldn't *even be able to pass out potassium iodide in inclement weather, because you wouldn"t be able to get around to the doors if there's six, eight, nine feet of snow.
So they're already sheltered and theY'll have* to stay there.
If the accident happens with nine t:eet of snow, some serious considerations (Laughter.)
There are three basic protective measures for provision CHAIRMAN HENDRIE:
I might be willing to regard that as Class IO.
(Laughter. ).
CHAIRMAN HENDRIE:
And just not plan for that.
MR. COLLINS:
Right.
There are three basic protective measures identified for the ten-mile emergency plaMing zone, which went forward to you in a SECY paper,* and those are evacuation~ sheltering, and thyroid blocking. That's what it comes out to; o.r a mixture of those four actions.
The uitimate, of course, is.. evacuation.
MR. GOSSICK:*
Beyond that, though,. suppose there is an evacuation. The qtiesti on then is, is it. safe to come
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37 back: or when is it* safe* to come. back.
And that-' s a part that, you know, I guess we still say, stay involved in.
Is 3
it going to be our responsibility or.whose will it* to make 4
-that determination as you see it?
~
MR. COLLINS:
To re-enter the area?
6 MR. GOSSICK:
Yes.
7 MR. COLLINS:
I think that will probably -
if 8
that ever comes to pass, where people have to leave because 9
of radioactive contamination of an area, I would think that 10 such agencies as this agency, HEW and EPA and FEMA would 11 jointly make such determination as to. whether or not they 12 could go back in; HEW from the standpoint of foods, 13 watershed areas, milkshed areas; EPA from the standpoint of 14 1 :5 people; HEW fromi the standpoint ot people.
I would think that these two agenc i*es would have a 16 big role iri determining whether or not people* could go back 1,
into an area *.
18 COMMISSIONER.GILINSKY:
But that isn't something 19
- in which minutes count.
In other words, there is time to 20 do that and improvise if nee e ssary.
If someone gets back a 21 few hours later, it's* not the-end of the world.
22 23 MR *. COLL INS:
Right.
- CClMMISSIONER.GILINSKY:*
But it is important to be 24 *.
able to:.take.** a~tion on e\\,acuation, if that-'s "called for, 25 promptly.
And that's some.thing. one has to be prepared to
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MR. COLLINSz Right.
If I can go on, a couple of other items in, C-1 and c~3 specifically relate mainly to guidance, existing guidance and forthcoming guidance.
And it al so encompasses not only guidance that this agency has produced, but guidance that other federal agencies have 8
produced or have not produced, which is needed.
9
- We are, in the {)ffi ce of State Programs, at this 10 tima looking at the existing guidance for state and local 11 govgrnments and what are the problems with it. Al though 12 it's fairly comprehensive,.one of the things that we know 13 has to, be done is to delineate,in the guidance for 14 l:S emergency pl ans more clear1y the kinds of ~hings that belong to local government planning and the kinds of things that.
16 belong to state government planning and the kinds of things 17 that belong in the pi'ans of both levels of government.
18 We are acquiring some expertise from local 19 9overnments.
To do_this, we already have a temporary 20 employ.ee on board who is a county -- former county employee, 21 with* some experie*nce in.* plann.ing.
And we are ge_tting out an
.22 intergovernmental personnel fellowship, probably to arrive
- 23.
Sunday of* this week,.a: county civil defense* director from 24 25 Westchester* Count)/ near :fndian. Point, who wi 1:1 come aboard tor thr'ee months under an intergovernmental* fellowship.
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And these two 1entlemen, to try to help us in giving us some advice as to how to separate out this 39 3
guidance as Lt relates to the local governments and state 4
governments.
I think this will be a useful exercise and we 5
certainly need the help of these people, because we haven~t 6
had any people on the staff with local government experience 7
before.
8 9
10 11 12 13 14 15 16 1 '
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'036 12 0 I MM mte 40 HE~ and EPA have a substantial piece of business
,2
- to do, ~nd I notic~ the Chairman sent off a letter the other 3
day to HEW recommending that they complete their work on 4
.protective action guides and publish it as federal guidance 5
forthwith.
And I was glad to see that letter go forward.
6 8
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18 19 20 21 22 23
- 24 25 Dr. Hendrie and Mr. Macy also discussed the business on potassium iodide policy.
CHAIRMAN HENDRIE:
We1 ve got one item, John.
We can put a check beside that.
<Laughter.)
MR. COLLINS:
Under B-6(a), I think we can say -
so we have some work Ctit out for us in revising our guidance.
And we also have to look forward that if the Hart legislation or something like it comes down the pike, we have got to have a weather eye out £or it, converting the guidance or codifying~the guidance into some kind of a regulatory mode.
And of course, we would look into the Office of Standards Development to pick up a big chunk of that kind of activity, if it goes that way.
One thing I would like to take just a moment on, at least for my own part -- and I think I would speak for J
Mr. Grimes with NRR -
we would like the Commission to act on our SECY paper on.. the emer.gency planning zones, if they can; as soon as they *can*, because we think the
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- 24 25 41 establishment of these emergency planning zones as re.commended in that paper is the necessary framework that we all.need to put our guidance into better-shape.
So I would hope that the EPZ business can go forward soon.
CHAIRMAN HENDRIE1 DoesnJt that preempt a piece of*
the rulemaking we are trying to carry out, or does it?
COMMISSIONER DILINS.KY-1 If it doesnJt, it ought to.
~
COMMISSIDNER AHEARNE:
Since I have already said it should,. I guess I have already ans.we red that f,or myse 1 f *
. MR.* COLLINS1 Those of us.who spent a lot of time on that SECY paper and the two and a half years -on the task force report, we.were a little upset when we saw that go into the advanced notice of proposed rulemaking as.one of the 13 or 1-4 points.
But,nevertheless, it got in there.
But we think that at least a policy statement on EPZs might be -
basis.
.COMMISSJONER AHEARNE:
I think we can endorse it.
MR. COLLINS-:
advisable, at least on an interim I would like to make the obse.rvaticon that several states are already running. with the emergency planning z.one concept and seyeral utilities have indi.cated to. us that they are r-unning wi.th it as well.*
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10 11 12 13 14 15 16 1 7 18 19 20 21 22 23 24 25 42 COMMISSIONER GILINS.KYa Couldwe bring that up for consideration?
COMMISS.I:ONER.AHEARNE:
You can agr.ee with*the memo I sent.
.CHAIRMAN HENDRIE:
Never mind the lobbying over there.
Having ~ited the item, Len, in the notice of rulemaking, so that in principle it is an issue.to be
. discussed, considered. in that rulemaking, suppose we wanted
- to pull it back out and deal with it separately, so that it would either* be a given i_n the r.ulemaking or -
COMMISS.l.ONER AHEARNE:
- It-'s one pie-ce, because what the rul,making said is, asked fbr comments on how the
. recommendations of it outjht to be implemented.
There are a number of implementations -
two -zones or one major -
agreed, a major implementati.on.
So I think the question really ought to be if you pull that piece -0f it -0ut.
MR. BI.CKWITs You can pull anything out of* that rulemaking *.
CHAIRMAN HENDRIEa
.I presume what i-t. would require would be simply Commission action and publicati-.on,of an amended notice.
MR. BTCKWI.T:
That-' s right,*,.or you may decide that you don-'t.want to. go throughthe process in order to take a particular action *.. - In that.case, you can take it by
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9 10 11 12 13 14 15 16 1 7 18 19 20 21 22 23 24 25 43 policy statement or an immediately effective rule.
. MR. JAMGOCHJAN:
Excuse me.
I., d like to make a point.
My name is Mike Jamgochian, from the Office.of Standards Development.
The policy statement.itself really addre.sses the EPZ and emergency planning considerations to state and local governments.
The rule change does not address anything to state and l.ocal governments.
The rule change :is primarily focused to requirements to licensees and applicants.
It.,s two separate things.
CHAI.RMAN HENDRIE*
You would regard it as separate e11ough?.*
MR. JAMGOCHIAN~
I have.
CHAIRMAN HENDRIE*
S6 I can either agree with the paper or disagree with the paper oi something in between, and that
.MR. JAMG.OCHIAN1 The policy statement says to the state governments. we think you should plan out to 10 miles and 1 5 miles.
The proposed rule.change that you people have be.fore you n.ow talks to a licensees A licensee shall make
.a_ppropri.a.te arrangements* bey.and the LPZ out to an area called. the EPZ.
But again,: they are addressed to separate. pe.ople.
CHA I RMAN HENDR I Ea - I s_ ee.
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16 1 7 18 19 20 21 22 23 24 25 44 COMMISSIONER AHEARNE:
Vic, just ini t ia 1 it.
CHAIRMAN HENDRIE*
You want to show me where to sign it now?
C Laughter. >
COMMISSIONER AHEARNE1 I:'.11 send you another copy, just in casB you might have put it somewheres.
.CHAIRMAN HENDRIE&
Put an X where I should sign.
<Laughter.>
MR. COLL INS:
One of the_,othe.r items-,.F-3, de alt
~1th training and retraining.
As you are aware, gentlemen, we have a fairly,substantial training program with state and local governments under way.
..One of the.criticisms -of that training program ~as that there were*no provisions for retraining o_f per_sonnel to replace personnel at the state and local government who attritio.ned -out.
_ The turnover rate among state and local governments in some areas is quite high, and :one of the reasons we did~t develop.any retraining pr:ograms was we were Just barely abl.e to keep our heads above water training
_ people who had *neve.r ;been train.ad be.fore, -and our budgets were limited.
Our FY -'80 budget is substantially increased -over
- what we had be.fore..
It"'.s.. about.$8'00, 000 a year, and we are taking: a, look' at:.now-the, retraining needs,of the state and local governments*. - And r feel we will be able to make
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45 progress in that area~
Another i tern in there, A-3, funding, dealt with, in the main, Dr. Solomon's funding study which he has -
COMMISS.LONER AHEARNEs Before you move to that, while we're still on that partic,ular.~3, could you say a fe.w words on.what you have in mind on the.c.ertification,
- federal certification of the emergency planning?
MR. COLLINS.:
Of emergency personnel 1 What we had in mind there, Commissioner Ahearne, *was that we would suggest to FEMA, and we are prepared to suggest to FEMA~
that they -~stablish the *mechanism t.o ce:r-ti_fy the personnel by some means.
We have the existing training programs in place.
The courses are in place.
- ItJ s just that we don"t have a certificati.on procedure. _ What a pers.on gets when he comes out of one of the.se training. p.rograms is a certificate from the contrac,tor or from the NRC, whoever is conducting the program.
So we would look to FEMA to establish maybe some kind of a. certification me.chanism.
In*-other words, a person could gat a certificat**if he attended a special certification qualificati.on.
- lf he attended all of the-emergency planning; and prep_arednes s program courses that *are
,offered; he::,.. might get. -some kind: o.f a rating of A,or something l{k~ th~ti~~~d if he attended just certain,ones
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This might help the states in determining which of their people were qualified to do planning and which were qualified to do response ~perations and so forth.
We think itJ s a decent idea and we would look to FEMA to certainly properly assume the_ role in cer.tif-ic-ation.
The funding study, Dr. S.olomon"'s report, NUREG-0553, ~ill be probably out of the print shop any day now.
It was already out in dra.ft form last spring.
And what we intend to do with the funding. study is to ensure that it gets up to.the.Commission with some.options and so forth and, more importantly, that it get to FEMA.
Because we think the document will be*a.very good first cut look at the funding problem at state and local government level for
.FEMA.
We do~t think FEMA has we know of no such study that has been made *for FEMA or for NRC in the past, and it sho.ul-d be useful to them, in addition to this agency.
I would expect that the bulk of any a.cti-on
-conc.e.rning funding that would be taken as a result.of this
_ study -and any forthcoming studies after tha.t would be undertaken by F.EMA, because*. they* 1ook like.they are going to
- be the moneybags o.utf i,t of the Federal Go,vernment.on
.emergency*planning_preparedness.
We do have some funds in fiscal..,80, -.$500,000, '
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10 11 12 13 14 1 5 16 17 I 8 19 20 21 22 23 24' 25 47 if that-co~es through, where we can put that into some problem site areas for emergency planning around the country.
And we are thinking about possibly the county
. areas.around* Indian Point, as a sort of an interim funding measure there.
Items D-2,and 8-6 relate to mainly field assistance, our field ~ssistance program and our concurrence program with state and.local government plans.
- We have expanded our field assistance effort.
We have three people from,Nuclear Reactor Regulation assigned to.the,Office of State Programs to help push the review and concurrence function with the states.
We have a commitment from all states with operating reactors, with an estimated.date when they feel
- their plan would be able to get a concurrence using the existing guidelin~s~
These date~ range all the way from this month a 11 the.way o.ut to June of 1980 for the last state, whi.ch w.ould be I 11 inoi s.
Illinois has a lot of work to*do and.they have indi~ated that they will have a draft plan in to us in December-and pr-obably' a plan r.eady for concurrence in June of.1980.
I think.they,are all trying to be,at the dates that are set* fc:>rth J.n :th; Hart legi.slation~ and as long as we have an *augmentation of personne1 i.n our,office and get the
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- 11 1 2 13 14 15 16 17 18 19 20 21 22 23 24 25 48 a ss.i stance of the other involved offices at,.. /the regional level, the other federai agencies, I tbink we can pull it off and at least get the plans up_to the level of meeting today-"s criteri.on guidelines_-a.s a first step, and then later implement the concept _ot-emergency planning zones, if the Commission gives us/the green light on that.
We wouldn--'t expect the states to be able to hang the EPZs around each facLlity immediately.
They would take some time to. do that, probably by about January of --'81.
The response to the Chairma~s letters to the states concerning concurrence has been overwhelmingly good, and~e have seen no letters come back from any states I
indicating that they don-'t want to cooperate in the existing concurrence program.
Finally, the last i tern,.which is B-5,- wh.ich is research.
A c.omment was. made during the deliberati.ons of the task force that someone.ought to take a look at the research that is going on in the emergency preparedness area and the la.ck of research that--'s going on.
And our,office volunteered to try to prepare a laundry.list of all the research activities in emergency preparedness that we know are going on, not.only in this agency, but in other federal agencies, so that* then.we and the -other federal agencies can look at this and, see--what needs to be done and.what.1s already being done.
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10 11 12 13 14 15 16 I 7 18 19 20 21 22 23 24 25 And we would hope to have a look-see at what is going on in research inside and outside the agency, and have a list of that activity, and then be able to make some proposals for additional research by the middle of this fall, I would think.
I think, Tom, that finishes my presentation.
MR. CARTER:
Mike Jamgochian.will.discuss Office of Standards Development.
MR. JAMGOCHIAN*
Gentlemen:. The Office.of Standards Devel.opment plans to resolve everybody's problems bY writing.regulations
<Laughter.>
MR. JAMGClCHIAN-1 quick and easy.
COMMISSIONER AHEARNE:
That-~s emblazened over your doorway,_ by the way *
. <Laughter.>
MR. JAMGOCHIAN:
Basically, what I wanted to do
.was, rather than go over specific problem areas laid out in
- the actton plan~ go over rules, regulations and regulatory guides.that we haye written, are in the process of writing, or what ~e plan on doing.
One,of the problem :areas that sur_f aced was emergency planning for*research reactors, and also maintaining emergency plans up to date.
We.wrote.a rule chang*e.
The Commission approved the proposed rule change.
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It is to be published in the Federal Register either tomorrow or the beginning-.of next week.
50 Second, there is a rewrite to Appendix E to 10 CFR
-50, as well as~ ~hange, proposed change, to 5033 and 5054.
You received the last few pages to the task force report, a first-.cut draft of proposed rule changes.
Now, this first cut.was simply my own_personal draft as a result of sitting down listening to a number of Commission meetings, your concerns in emergency planning, and sitting down with the various offices, getting their ideas.
It was done very qui.ckly, and attached here primarily in the hop.es that the Commission.. co.uld give me an
,idea if they have any major problems with the concepts that
, I have laid out in either the change to 5033,.which is condition of an application, 5054, conditions.of a licens~,
and the rewrite of Appendix E.
As of September 1st, I started writing the formal Commissiqn paper which lays out the discussions, the alternatives.
I anticipate getting that through Office review and to the Commission the latter part -of September, which, as you probably know, is one week off the schedule that you have directed f-or that rulemaking *
. MR*~-- -G.OSSICK,:.:
Mike*, that wi 11 have the comments incl,uded tha.t we have, received or not.?
MR'. JAMGOCHIAN:
Well,* there-'s a problem, as with
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We recsived a great number of comments.
As of today, I believe we received 95 comment letters.
Each letter letter.
.well, approximately maybe five to ten comments per Well, as of the 1st of September, in order to meet your schedule, I had +/-o start writing the rule, the Commission paper.
We had only received approximately 30 comment letters.
I evaluated those comments, reviewed them, and took into consideration all the people1 s c.oncerns in writing the Commission papere Well, now, since September 1st and as of today, we received a significant number more.
So you know, I propose to ~nntinue forward because of the urgency -0f the matter and present the paper the latter part of September, with the c.onsideration of 30 comment letters.
If the Commission doesn't lik*e it that way and wants me to consider,a 11 the c.omments, you've got to give me more.time.
COMMISSI.ONER AHEARNE-:
Is there any.one who is looking at the other 65 to see.what major points are made throughout that?
- JAMGOCH I AN.z Th atJ s me *
. COMMISSl.ONER AHEARNE-1 Yo~ re the only person.?
JAR.. JAMGOCHI AN.1 Yes, sir.
No.w, the. other 65 -
as of today, I anticipate we
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- 52 are going to get 300 letters.
This re.ceived a a great deal of Pub! ic i ty in the newspapers.
S,o
- we.are getting quite a bit.
So if we want, I can keep reviewing letters.
We1 re going to get them.
COMMISSI.ONER AHEARNE-1 I would guess -
let me shift my question over two notches.
Lee, is it possible t.o talk to Bob to see if it-'s possible to find someone else to help Mike in reviewing these?
.MR.,GOSSICK1 We obviously have to look into. this to see if.there is some way o.f task forcing a* revLew of
- comments.
You know, if the first 30 represent --
.COMMI SS I.ONER AHEARNE1 And having that done, the task f.orce n.ot end up being.M.ike in a different suit.
MR.*.. GOSS ICK:
J understand.
- MR. JAMGOCHJAN-:
Again, it-'s as of today we have
_receive.ct 95.
So y,ou-'ve got :to have* a cutoff point in orde.r
.to proceed.with,the Commission paper and with rulemaking.
COMM! SSJ.ONER AHEARNE:
1 understand, but there
_really has to be more. per_sonnel.
MR *. GOSSI.CK::
When does the comment period end, Mike?
MR" *. JAMGOCHTAN-1 The comment peri-od ended the 1 s.t of September.
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53 MR. GOSSICKs So,these are late comments,* in.
MR. JAMGOCHIANs But that-"s usual."
MR. GOSSICKt That-~s normal.
COMMISSIONER AHEARNEs So you really need someone else to help re.view those.
MR. JAMGOCHlANs What I anticipated doing was, yes, continue reYiewing *them, and if there-'s any major problem,* then surface that when the.Commission reviews the proposed rule changes.
But again, this is only proposed r.ule changes, *it-" s not effective rule.changes.
What I had ~nticipated doing was, prior to writing
- the,Commission paper.on the final rule changes, is have a thorough detailed analysis of all comments.
To address one.of the questions I believe you had re.lative to the EPA-NRC :task f.arce, the comments that I re-viewed, the 30, I did a fairly thorough evaluation of them and none,of them, as of September:.. 1st, had any problems with the. EPA~NR.C.:task fo.rce repor.t.. T.o be fair, many of them had never heard,of 1 t.
.( I,.aughte r *.>
I have sent -out 10,or J 2 EPA~NRC.task force reports to c.oncerned.citizens.
- . B.ut.to try.to loo.k at,the questions that were sent out in the-Federal Register nottce, y.o.u know,. it-'s a lot.of
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to t J 1 2 J 3 14 15 16 17 18 19 20 2J 22 23 24 25 54 conc.ern to people at home that are simply saying,' I live
.three miles or f.i.ve mi.les from the plant and I-'m w,orried.
They ~re truly concerned.
Well, that EPA-NRC task f.orce recommendation in
- essence takes into acco.unt, because w~re saying, all right, we have.to have emergency plans out to ten miles.
So may of them are concerned that they never heard of an emergency plan and that.they live four miles,* five miles, down the road from a nucle.ar power plant.
So when I said. that, they would like the concept
,of emergen.cy planning.out to that distance.
Many.of the.
.states -
well.,.not many.
A few of the states, in glancing thr.ough the.other 90, the states had said that they were conce.rned.as to NR.C~s r.o.le during emergency.'
Is Harold Denton going to come down.and take.over everything as soon as.an emergency happens, that kind.of.a.thing.
It.was sincere concern.
You know, why shoul.d we plan if.NR.C.is going to take.over the ballgame.
So that was a-c.once.rn *
. CHAIRMAN HEND.R.IE1*
We only book Harold one engagement at a. time~-
.MR. JAMGOCHIAN*
- And.as.of Septembe.r-.1 s,t,.we had no.comments. from* the.. utilities.*.
a
- .** ** Relative *.to, the0.Appendix* E change, I would like to simply* go*.over.the.. major.-.changes.
Bast.ca lly, we have
-~~
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10 1 1 1.2 13 14 15 16 I 7 1.8 19 2-0 2.1 22 23 24 25 55 required that implementing procedures be submitted as part of the FSAR for staff review and approval.
These are major changes.
Number two, we have extended emergency planning consideration of licensees out to an EPZ; and, number three,
.requiring as a condition of an applicati.on.and license that state and_ local* g.overnment emergency response -plans be submitted and concurred in by NRC.
Those are the three big changes.
The other changes are, if.. you _would, sharpening, clarifying, Appendix E, being more.specific where it has been per~eived that it hasnJt been specific enough.
Basically, that's the,change in Appendix E.
Dnce Appendix Eis ~hanged and approved in final ru.le form, -I anti.cipate on pro.ceeding-with revising Regulatory Guide I. I OJ as we 11 as Regulatory Guide 2. 6,
.which is emergency -planning f,or research re,act.ors, and Regulatory,Guide 3.42, I be.lieve it is, emergency planning for Par.t 7 pe.ople.
.COMMISSIONER AHEARNE:r
.In your perspective, what ought t.o be the. sequence of.those changes.w-ith respect to the r.ulemaking.?
- - MR.;. JAMGOCHlAN*.
Wha.t.do you me.an by the_ sequence.?
- COMMISSIONER-AHEARNEa,. Should the emergency
.. planning_ rulemaking.be finished first before you make those
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- Two regulatory guides?* Well, the basis for.the regulatory guide is a rule.
The foundation is 3
the rule.
4 COMMISSI.ONER AHEARNEs Yes, s,o that we really 5
ought t~defer real consideration of those until after we 6
finalize the rulemaking.
7 MR. JAMGOCHIAN:
Most definitely.
I thought I
/
8 brought that out.
nnce Appendix Eis written in its final 9
form~ then* IJ 11 pr.oceed with rewriting regulatory guides.
10 I 1 1 2 Basically; thatJs it.*
Any problems?
(Laughter;)
COMMISS.lONER AHEARNE&
The largest problem is you 1 3 don-'t have eoough* people to help you:
14 MR. KENNEKEs Let me ask you a question. fo.llowing t 5 Commf ss.ioner Ahearne. lf you say you must have a rule 16 be.f,o.re you can get the guides, neverttle less one,of the 17 elements of the rule is that the licensee submit a state 18 plan; which in turn must in.corp.orate local plans.
19 What are we doing to provide the guidance, in r
20 upgrading the guidance to.. the locals in particular; so that
\\
21 whatever,the 1 i.censee submits will be acceptable. and meet 22 whatever cr.Lteria we have.?
23 We need to go. forward on both elements together.
24 25 MR~ JAMGOCHIAN: - _ We 11,- the criteria for accepting or concurring. in.a state plan has.already been set,out
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57 by State Programs in NUREG-75111.
COMMISS !ONER AHEARNE:.
- But i tJ s a tittle weak, as has been pointed out, on where the state is and.where the local is.
I think Al MR. JAMGOCHIAN:
Basi-cally, weJre going on whatJs on the books now.
As a condition of applicati.on and as a c.ondi tion of 1 icense, a concurred-in state plan wi 11 be required, ac.cording to the regulatlons.
.MR.*KENNEKE:
No change_.from present criteria as reflected in 7511?
MR. JAMGOCHIAN:
Correct.
The action as it stands today.
COMMISSIONER AHEARNE:
That, of..course, is one.of the ~hings that the rulemaking is addressing1 MR~*.. JAMGOCHIAN:
Concurrence.
MR.*. KENNEKE I lt may not be
- COMMISS.IONER AHEARNE1 Also,. what ought to be in the Off,ice of Local Planner.s.
MR. JAMGOCHIAN-:
_Not in this rule.change~
The Hart bi 11 says that the.cri terta f,o.r concurrence wi 11 then be put in* our regulations.-*
COMM.ISSJ'ONER. AHEARNEz What..I am saying is at
.least a notic:e_ for* rulemakingt had.a.ddressed one of. th:e.
Lssue s.of what. -are the*,.cr:i teria; MR* *.
- JAMGOCHJAN-1*,Oh,. yes; the advanced n.otice.
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58 That-' s true.
COMMISSIONER AHEARNE:
So at least I trust, since that was in the advance.d n.otice, it to some extent wi 11 be addressed in the rulemaking.
MR. JAMGOCHIAN*
Not this particular rulemaking; another rule making at a later date. 'The advanced notice went out.with a lot of general que s.ti.ons:
.What do you pe.ople thin.k about emergimcy planning?
You kn.ow, very general questions.
And we-'re getting very general -
in many of them; very general comments.
COMM! SSIONER__AHEARNE*
Yes.,
I think some of those general* ques.ti.ons were -- under the assumption that the rule would answer those general que..stions specifically.
MR. KENNEKE* -M~ke has gi.yen the.,~raft rule, and -
it goes only to the requirement that a licensee submit a-plan; It does not specify the ~riterion ~s part of the guidance I assume you are seeking -
_MR. GOSS I.CK.a That's intended to be a separate rulemak ing with regard.to the guidance to the state.
MR. JAMGC1CH1AN* - That-'s correct.
We cannot put in
.our.rules right.. now regulatlons to states..
We have no right to regulate states..Our regu.lati.ons, as I understand them,
.a_r.e '.p_rimarily,to*- ltcen~*ees and applicants.
-_ COMMISS-10NER AHEARNE-1, Certainly;*
We can certainly say; c.an-'*t we; that,--.here, lf..censee, we are
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10 11 12 1.3 14 15 16 I 7 1.8 1 9 20 21 22 23 24 25 59 telling you you will not get a license unless the state plan haS x, Y, z in it?
MR. JAMGOCHIAN:
Yes.
COMMISS !ONER AHEARNE:
Can.J't we. do that.?
MR. BICKWIT:
I assume that we are proposing you are contemplating a proposed rule which would say that.
MR.* KENNEKE:
That is not in Mike-' s proposal.
MR. BLCKWIT:
What is in your proposal, as I under.stood it, was a re.quirement of a concurred-in state plan as a condi ti.on* to a -1 icense.
.MR *. J.AMGOCHJAN:
Yes, sir.
MR. BICKWIT:
If you can require that as a condition to_a-license, you can.require that it say ~ertain things.
MR.* JAMGOCHIAN-:
Okay.
MR. BICKW.IT:
As 1.re.ad the advanced notice for prop.osed rulemaking; we were go.ing to confront that issue in the rulemaking,.. Just what.cr.:i taria should we prov.ide to the
£tates and localities.
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60 MR. GOSSICK: *. The point Mike made is that guidance such as this.is what you need to start putting together the final proposed rule.
MR. JAMGOCHIAN:
That's true.
5 But to lay out more specifically the acceptance 6
criteria for state and local government concurrence in our 7.regulations now is.much broader in scope than I had anticipated.
a Again the rulemaking proceedings that you had directed 9
originally is under very stiff scheduling.
10 11 12 COMMISSIONER AHEARNE:
Right.
MR. JAMGOCHIAN:
If the scope has to be expanded MR. BICKWIT:
Just one relevant factor.
In the 13 Hart Bill, within six months of enactment; theCommission 14 would be required if the bill *passes in its present form, to 15 have-promulgated a stepup in the criteria for states and 16 localities. It said,_ in effect, if that schedule is to be met, 17 then this would appear to be the appropriate rulemaking to 18. deal with :that issue.
19 MR. KENNEKE :-
If I may follow this up' as I 20 understand, both NRR and State programs as they look at both 21.. sides.of. their act+/-on plans, one with state plans and one with 22 licensee plans, are looking at local plans under.the present 23 criteria?
.24
. MR. CARTER:
I think they should speak to that.
I Ace-Federal Reporters, Inc; 25 would ass.ume, they* are.
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'25 61 MR. GRIMES:
Yes. The test teams for NRR are looking at the adequacy of the plans around the facility which includes the sta:e and local plans, and would have some draft or interim 0
criteria that we are using, end we will have some action level criteria also for interim use which we will be getting experien e with over the coming months and will undoubtedly we will change and develop as we use it.
So the answer is NRR will be looking at that.
I am not sure the extent to which State Programs in their current exercise is looking at focusing on locals because they are using the same criteria as of July 16, specified in the Hart Bill for their concurrence exercise.
But there is some look at local plans through the team effort.
MR. COLLINS:
Collins, State Programs.
We are looking at local government plans in the same light that we have paid attention to them in the past.
In other*words, we are looking for them as a part of the state-plan.
Right now we are in a mode*as I explained, of tryirig to be a little more definitive. with respect to what we.expect to see*in, the local*plan, vis a vis our existing guidance and wha:t we*expect to see in the state plan and what should be. in both.
Naturally, since we haven't paid a great deal of attention to.separating*the* guidance elements at state
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10 11 12 13 14 62 level or local government level before simply because we didn't have the staff to do it, and to look at local plans, we are in kind of a mode right now what should be in local plans.
But we intend to work with Nuclear Reactor Regulation.
And I think between the two offices we can quickly straighten this out.
MR. GRIMES:
With respect to rulemaking I think it is a question. of how much detail you want to put in the rule.
You can take these draft documents, guidance documents and put them out as the proposed rules, I suppose.
But I think that is a good deal too detailed, given our current state* of.development of the documents.
COMMISSIONER AHEARNE:
Mike, am I correct that you l5 are the only person working on this advanced rulemaking?
16 17 18 19 20 21 22 23 24 Ace-Federal Reporters, Inc.
25 MR.. JA.~GOCHIAN:
Yes, sir, in the Office of Standards Development.
COMMISSIONER AHEARNE: But you don't have other people working with you?
MR. JAMGOCHIAN:
No, I'm the bottom.
(Laughter)
COMMISSIONER AHEARNE:
Or the top.
(Laughter)
For example you don't have an ELD lawyer.full-time working with you?
mm4 63 MR. JAMGOCHIAN:
No.
2 See, after the task force had this task force 3
report submitted, we wanted a rule change to attach to it~
4 I did have ELD input into that rule, into this package that 5
you got, as well as NRR, State Programs and I&E.
6 7
COMMISSIONER AHEARNE:
I recognize that.
I'm.really trying to make sure that I understand 8
and I think I do.
Thank you.
. 9 10 11 12 13 14 discuss.
MR. GOSSICK:
He is the Lone Ranger *
(Laughter.)
CHAIRMAN. HENDRIE:*. Very good.
MR. JAMGOCHIAN: Thank you.
MR. CARTER:
We do. have one other section to 15 CHAIRMAN HENDRIE: Can we move briskly to it.
16 MR. CARTER: Yes, sir.
17 Mr.* Durst?
18
. MR. DURST: *Gentlemen,* it is my purpose to briefly 19 review that portion of the task force review called the NRC 20 Actions Plans*, which is the first of the action. plans attached 21 toi:Appendix*~.,_3;-'-to:~the report:~s enclosure 3.
22 I might say I. got this job of having the perspective 23 of the-EDO or the* NRc.: with Mr. Carter,. - when: working with the 24
- task force when. it was* first put together, assigned me Ace-Federal *Repo"ers, Inc.
25*
- some representative; research as the. least involved person:.both
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25 64 in past and the future of the subject.
The first task of different tasks he gave.me, was that of critiquing the present status of NRC*defining implemen-tation and everything associated with emergency response.
He has already cited the results of this effort, which were achieved primarily by the working group under the direction of Mr. South and some slight help from me.
These are contained.in th~ report *.
I think I wou.l::l agree with Tom that the work they did deserve high compliments.
I think it is a decisive analysis of what is going on and whatever the NRC may do to take future actions, they should surely start with the address of the problems identified in this plan.
Sec'ondly, -as the task force was coming to its, reporting time, Mr. Carter asked me-then to take the action plans submitted by the action offices that was required, and attempt to summarize those more 6n a*linear basis than an analytic basis and to make some limited analysis of the value which they had as a basis for -future action by the NRC in achieving its overall policy.
The results of this. are contained in the action plan, specifically pages.3 through 5, summarize what has existed in the. *past, and include the fact that Mr. Jamgochian has been.the Lone Ranger for a long time in the Office of Standards-*..
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9 10 11 12 13 14 15 16 17 18 65 And posits the estimates of each individual action office in what it views will be its requirements.ioJIDeet their responsibilities.
The rough figures are that summation of these action plans connotes a threefold increase of resources or something on the order of 16, to add an additional 44.
The action plans were less precise in dollars.
Some. dollar figures-were cited and a deduction can be that dollars might be roughly not dissimilar from the figures that were cited for manpower, although were not dealt with in that detail.
Having analyzed the plans, some preliminary results were made. - These results begin on pc;1.ge 6, and they state I think in a pretty agreed way that the short-run* recommendation of the task force, parts cf the schedule which is at Table 2, provides fairly reasonable compliance wiht the wishes which*.:the Commissioners exhibited, and the timetable that you wish to follow*-
19 20 It is a possible schedule but it is not an easy schedule as Mr. Jamgochian has* just said.
But if we desire 21 to meet that schedule, or if the Commissioners or staff do, 22 23 24 it is indeed possible* to squeeze and come very close to. meeting it.'
In the lorig range the product of the task force Ace-Federal Reporters, Inc.
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I think tions of the task three points:
66 on page 8 which summarizes the recomrnenda-1 force for the long range are really essential]y I
The first, that the task force should be dissolved, which -- the reasons for which are stated quite extensively.
Secondly, that if in response to the requirements which the new. rules impose upon the public we will require again an:_
by the NRC over an.extended period of time.
Explicitly, the action plans did not address one of the elements which was contained in many of the topics put forth by the working group, and that was that there is and has been a lack of coordination among some of -t~e policies which NRC has put together, and perhaps in some cases even confusion.
Stated previously, and I_-*.".. just cite it, a lot of this does come because resources devoted to this thing.*.
quite limited it to that.
But* at the same-time it was the.feeling of the task force* which does. agree wi th.. ihe. recommendations on page 8, that if the NRC is to increase its effort in this field,
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23 that some more positive means of coordination will be required.
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25 67 over the long run, a concerted effort by all offices, seems reasonabl*e.
I have nothing else.
If you have any questions --
COMMISSIONER AHEARNE:
Perhaps you might address MR. GOSSICK:
Well, I think clearly what we have been doing here this afternoon points to the need for some better management approach towards integrating all of.the various items and actions that are going on in the various parts of the orgahization.
I guess one can start with one solution of trying to pull it all out and.put it together.
I frankly don't think that that's a workable solution.
COMMIS:SI:ONER. AHEARNE:
Why not?
MR. GOSSICK:.
I just believe too many of these things are so intertwined with the I&E ftinction,with the NRR
. function, that if you take it away and have a central office in charge of it, then*when you come to implement an action, an emergency response of some sort, you are going to have
- another problem of having the involved offices aware and curren up to date on what has been done*::with regard to planning.
Maybe. yo.u say, okay,. let. this office bei.in charge of the* event.
I don't really:think that that. is too good.
It has. problems.. It also has
- some attractions:.. in other respects.
COMMISSIONER GILINSKY: Wait a minute.
- The.distinction.of* being in charge of an event and
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mrn9 68 making sure that the various utilities and other localities 2
and so on have adequate plans and check them out beforehand, that is really what this group is doing.
State Programs isn't in charge of any. event.
The emergency people review the conformance to various Reg Guides and NRR are in charge of NRC's response to an accident.
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And there has been a gap, it seems to me, pretty clearly between on the one hand our review of utility plans in NRR, and review of state plans in State Programs.
And as far as I'm concerned, I think these two groups ought*to be brought together.
I'm not sure just where I would put them, and --
MR.GOSSICK:
I think that's a problem. And you
- 15 90 further and also take that part of the emergency planning 16
- function that I&E is also wrestling with --
17 COMMISSIONER GILINSKY: I think I might l?Ut them in 18 19 20 21
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23 24 I&E.
I'll tell you why:
Just as I think there is a problem in having a health and safety function-in*basically a liaison office which js:basi_cally what. State Programs is, I also think there is a certain conflict.in having anemergency*planning office in NRR *. And one of the reasons we haven't had' good emergency planning, is that,. I think to do too much. on that side seems Ace-Federal R epa"ers, Inc.
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25 69 And it may be that you want to have those responsibilities separated.
In other'words, those who review the plan shouldn't be assuming that their review wasn't adequate, there was an accident, the emergency planning will take care of it..
- In just the same way the emergency. planners shouldn' be assuming too much about how effectively the reviews have bee conducted and be too confident about avoiding any sorts of accidents.
So it may be that one wants to take it out of NRR, too.
In any-case, I do think it is important that these activities be brought together, particularly if. we are talking al:nut requiring State plans as a.condition -- and*
local plans as~ condition of licenses.
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MR. GOSSICK:
I certainly don't disagree with the
. need for tighter: integration and the possibility of moving it *all to one place or another, I think is something that would
- need to be studied certainly more carefully than we have delved into that.
'I think as an interim measure, at least an interim measure, that I think as opposed to the creation of a technical assistant_;;orsomething to serve as the central point for coordinating all this effort,*rrtaking sure that things'don't get. dropped'" in the. cracks,.. ; that problems. are elevated up *to
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9 10 11 12 70 where they can be dealt with and so forth, that I propose to, at least for the moment, assigning this overall role to the deputy, currently acting deputy EDO.
I may have to give him a legman to help stay current with-the program, because this is something that I think is almost a fulltime task for somebody cutting across the parts of the Staff where this activity is currently going on and trying to track reporting progress.
But the overall structure, you know, that is of more extensive reorganization and taking all, or at least parts of the current effort and putting it in one place is something that we frankly have not studied the ramifications 13 of.
14 15 16 17 18 19 20 21 COMMISSIONER AHEARNE:
Well, I asked you last week, to be prepared today to at least address that.
was my Item No. 4.
MR. GOSSICK: Yes.
..:That I'm not prepared to tell you that we have studied and.come up with alternatives, options and pros and cons of various organizational fixes.
COMMISSIONER AHEARNE:
I asked you for specific 22 things.
r.: asked you. to describe the formation of a separate 23 staff office, whose~~ :*: role would be to develop, coordinate 24 and insure the* implementation of. emergency planning action Ace-Federal Reporters, Inc.
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9 10 11 12 13 71 I think your answer is that you are not ready to address that'?.
MR. GOSSICK: Only to the extent that as far as coordinating the effort, assuming that you are leaving the functions where they are as opposed to trying to consolidate them.
COMMISSIONERAHEARNE:
I think the request is, is a consolidatiop necessary.
Certainly that is what I intended to write.
And I say which functions it would take over, it is a single office that would develop and coordinate.
MR. GOSSICK:.I think that is the subject of a study that -has to be very carefully done, and there *frankly wasn'.t*:.
1411 time to do it.
1511 If it is y.cb.ur desire that we undertake such a study, 16 II fine, we will do that.
- 1711 I think even if we* do though, for the time being I 18 II wouJd*.propose my going ahead with assigning the current 19 11 continuing responsibility of integrating and coordinating 20 II* this effort as. I have indicated.
21 22 COMMISSIONER AHEARNE:
I guess-I thought back when this emer*gency task force was being started, I can *.::*remember 23*11 one _of the. speclfi.c _questions you asked to: have addressed-I
- 24 II COMMISSIONER GILINSKY:
That's what I thought.
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I 25 II COMMISSIONER AHEARNE:: : -- was: to have it all pulled
72 together in a single office.
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MR. GOSSICK:
I don*' t believe that was in: the guidande I
10 11 that came through from Mr. Chilk, and I don't recall it being put in that many words.
Do you, Tom?
MR. CARTER:
No.
CHAIRMAN HENDRIE:
I don't recall it in those terms.
- I may be wrong.
MR. GOSSICK:
I think we reviewed that charter with you and our understanding of that charter, on June 28th --
well, if we missed it, I'm sorry.
12 COMMISSIONER.GILINSKY: Well,*I'd like to see it 13 brought together in one place.
14 CHAIRMAN HENDRIE:
What activities do you have 15 in mind?
16 Everything connected with emergency planning?
17 COMMISSIONER GILINSKY :. Well, I would certainly put 18 together the activities that are now presently in NRR with 19. those in State Programs.
20 CHAIRMAN HENDRIE: So that NRR would not have any-21 thing to do with emergency planning'?
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COMMISSIONER GILINS:Iq:
I didn't say where I. would 23 put them *.
We might put them in NRR.
But r* see a problem_
24 about doing that'..
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But I do*think it is better to have them together in
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25 73 NRR than separate the way they are now.
MR. GOSSICK:
I think I can perceive some real management problems with that.
Again it is going to be something that is going to take some study and careful looking at the implications_of this,resource impact, interactions, understanding with staff by this office, wherever it is, to do things like it currently is doing, field *surv.eys~and::-~all tha sort of thing, unless you provide a directive for that.
I guess another, just a point to mention, in creating a separate additional office is, I get a little concerned about, if a special:topic comes,iup, we keep adding another special office of some kind.
It suggests that either something is wrong with our basic structure -- maybe there is.
And also it adds a span of control, an additional communication problem.
You may have cured one problem. You have now created another set of problems to deal with.
Interaction communications, and so forth.
COMMISSIONER AHEAR..'t-IB: That's one of the disadvantage~.
Yes.
CHAIRMAN HENDRIE:
Especially considering that we start with a set of statutory offices which anchor major portions of the organization in a certain way, which we are not free to redeal.
Lam very leery* of establishing -- every time a
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If Problem A comes up, good, we will now have the Office of A.
Problem B, good, we will have the Office of B.
It is a random organizational approach which doesn't take account of the overall responsibilities for distribution
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simply a reactive response. Every time we get a problem that is causing trouble, good, we.need an office for that.
And they do their thing.
J Now we would have some problems with that.
That doesn't necessarily mean that some reconfigurin of places, arrangements by which we deal withfuese things
- aren't_appropriate and shouldn't be considered.
But I think we ought to come very carefully and with careful thought of a reorganization.for this purpose.
In.the meantime.I would suggest to you that whatever we may eventuallydecide about this,. that the Staff has to keep collected on all of these things going on tomorrow,.the next day and sd.on.
And.what the Executive Director is saying is that he proposes to establish responsibility to *.the Acting
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- who. would, on the Deputy's behalf,** be the cognizant engineer 23 for emergency planning *throughout the agency just to keep 24
- track of it in your. office.
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- .. **As: an* interim measure,.. that seems to me reasonable.
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7 75 It looks like these things are developing enough different elements in different places so that keeping track of it is a fulltime job.
MR.* GOSSICK: I think this is a subject *.certainly, if we get to the Congress with our supplemental-request, there is going to be interest in. And I would like to point to whatever steps we can take between now and then, not. only 8
actions, but the management of those actions.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 COMMISSIONER AHEARNE:
Certainly, it is entirely, as far as I can see, up to Lee if he wants to have an assistant in his office doing that coordination, that's fin~
with me.
I doubt that it is going to be an adequate response overall to have one person try to coordinate this. There is a lot of problems in the coordination.
I agree with Vic, I think we are going to have to at some point get to some additional restructuring of those functions. But*as a very* short-term interim, certainly that's -- (Inaudible.)
CHAIRMAN HENDRIE: All right.
May we go on that basis, with the understanding that you will look to the matter of what alternate structures might be better than the ones we have now to manage the business.. And wle1e then, you cut off the transfer.
That is, Ace-Federal Reporters, Inc.
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You just can't take the whole thing* out. You may take just the planning elements out, or even some more than that.
But you have to decide where that cut line is that you S
are going to transfer over into a separate office.
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- And, are you ending up in turn now making emergency planning~- just how does it fit in terms of agency priorities and the overall resource allocation.
MR *. GOSSICK:
I would ask Norm Haller to take this on like he did the safeguards consolidation study on the organizational studies.
And this is a four-bodied problem in that two-bodied problem essentially, and it will take, I'm not sure how much time required..
- Something in the *.nature of a few weeks to do.
- CHAIRMAN HENDRIE:
My guess is it will be more than l7 that by.the time we sort things out,* and interact with the 18 offices.
19 20 21 22 COMMISSIONER AHEARNE:
In theory there is a fair amount of thought.that's already been given, I'm sure, to the various, aspects of' it-on the task force.
For. me,. I would like to thank Tom and the people' 23 that worked on this.
This is certainly a very significant 24 piece of work with a lot: of hard'effort, obviously, to bring Ace-Federal Reporters, Inc; 25 us a:,. go6d Ttl'.ay: forward. on* this very difficult subject.
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- 77 CHAIRTvlAN HENDRIE: Yes,. I would like to join that sentiment.
Thank you very much.
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One last request is that when you
- respond to Sain on this, please remember that we have the Brooks letter to answer. In.the r?port we have got to tell*
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- the Congress what the Commission intends to do.
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We need to have your guidance.
COMMISSIONER AHEARNE: We have the Lone Ranger working on it.
(Laughter)
(Whereupon, at 5:30 p~m., the hearing in the
. above-entitled matter was adjourned.)
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