QUESTION 3. ANSWER. Please provide all documents the Commission has received related The only information the staff has received related to radiological response activities at Chernobyl is the Soviet report to the IAEA and the draft INSAG Committee report. A copy of these reports are enclosed. Prior to the August IAEA meeting in Vienna, the U.S. was preparing a factual report on Chernobyl, based on the information that was available at that time. Chapter 8 of that report dealt with emergency preparedness response and a draft was prepared by the Federal Emergency Management Agency (FEMA). For completeness we are including a copy of this draft. However, since the Soviets have given us an extensive accounting of the accident, this draft chapter is no longer relevant, and a revised factual report is being prepared. A copy of a preliminary internal NRC memo requesting initial contributions to the Chernobyl implications assessment is also enclosed. QUESTION 4. Based on the Chernobyl related information the NRC has received, what has it learned about the need for carefully coordinated offsite planning and preparedness activities at nuclear power plants in advance of an emergency? What does the Chernobyl experience reveal about the human factors involved in effectively implementing a radiological emergency response plan? ANSWER. As the Subcommittee was told in testimony given prior to the August IAEA meeting, the NRC planned, subsequent to receipt of the Soviet report on Chernobyl, to complete both a factual report on Chernobyl as well as an implications assessment report. At this time, we are actively studying the large amounts of information provided to us by the Soviets, and have identified a preliminary list of candidate issues to examine for generic applicability to commercial U.S. nuclear power plants. This list is included for your information and includes a topic on emergency planning. We plan to complete our implications report by early December and at that time any further actions to be taken, including in the area of emergency planning, will be identified. However, at this time it is premature to speculate on the lessons to be learned from Chernobyl in the area of emergency response planning. Enclosure: Chernobyl Accident Candidate Issues Markey/NRR QUESTION 6. At an August 2, 1983 hearing before the House Subcommittee on Oversight and Investigations, Committee on Interior and Insular Affairs, David McLoughlin, Deputy Associate Director for State and Local Programs and Support, FEMA, testified, "Both FEMA and the NRC have initiated a joint, concurrent review of NUREG-0654, FEMA-REP-1, the major source of guidance to State and local governments in developing their plans and preparedness capabilities. Changes, if warranted, are anticipated beginning in fiscal year 1985. a) The existing source of guidance to State and local governments remains Revision 1 of NUREG-0654, FEMA-REP-1. What revisions have been made to the State and local government guidance criteria which are not reflected in NUREG-0654? ANSWER. FEMA has issued a series of documents designated as Guidance Memoranda (GM) that are used: (1) to set forth FEMA policies and procedures related to radiological emergency preparedness (REP) regulations, or general Agency policies, (2) to provide clarification and interpretation of criteria contained in guidance documents such as NUREG-0654/FEMA-REP-1, Rev. 1, and (3) to provide information of a more technical nature to support the implementation of the emergency preparedness program through the transfer of technology. Although GM's are not "revisions" to NUREG-0654/FEMA-REP-1, Rev. 1 in the strictest sense, they do explain how FEMA is interpreting that guidance. Enclosed is a copy of FEMA GM IT-1 entitled, "A Guide to Documents Related to the REP Program", dated October 1, 1985, that includes a listing of current FEMA GM's. QUESTION 6.b) What revisions have been made to the NRC/FEMA formal review process since 1983? ANSWER. The EP regulations were revised in May 1985 in response to a decision by the United States Court of Appeals for the D.C. Circuit which vacated the 1982 amendment to the NRC's regulations which stated that emergency preparedness exercises were part of the operational inspection process and not part of any operating license hearing. The basic effect of the Court's decision and of the rule change was that the results of pre-hearing EP exercises may be subject to litigation before the Licensing Board. The Commission also amended its regulations in July 1984 to relax the frequency of participation by State and local governmental authorities in EP exercises at nuclear power plant sites from annual to bienniel. Also, of course, the NRC refines its policy in case-by-case adjudications. Two such cases are the licensing proceeding for Diablo Canyon and Shoreham. The current Memorandum of Understanding (MOU) between FEMA and NRC (provided under question 6.c) below) contains changes dealing principally with the FEMA handling of NRC requests for findings and determinations concerning offsite planning and preparedness. The basis and conditions for interim findings in support of licensing are defined, as well as provisions for status reports when plans are not complete. Rather than being "revisions" to the NRC/FEMA formal review process, these changes to the MOU actually documented practices that had been followed in 1983 and the interim. QUESTION 6.c) Please provide a copy of the current Memorandum of Understanding between NRC and FEMA. Is the NRC considering any changes to the MOU? ANSWER. Enclosed is a copy of the "Memorandum of Understanding Between NRC and FEMA Relating To Radiological Emergency Planning and Preparedness" that was published in the Federal Register on April 18, 1985 (50 FR 15485). At this time the NRC is not considering changes to the MOU. QUESTION 7. Officials of Public Service of New Hampshire (PSNH) have stated ANSWER. As indicated in the July 29, 1986 letter from Public Service of New Hampshire, the applicant has requested the NRC to perform a technical review of the Seabrook Station Probabilistic Safety Assessment Update. Depending on the results of the technical review, the applicant may request a change to the emergency plan process for Seabrook but has not specified at this time what future action may be requested. QUESTION 8. According to documents provided to the Subcommittee, the Commission a) In light of the fact that PSNH has made no ANSWER. In view of questions which have been raised by members of the public concerning possible unique emergency planning problems at Seabrook, the staff considered it appropriate to review the Seabrook submittal to obtain a better overall perspective of risk at Seabrook. For this reason, the staff agreed to review the Seabrook Probabilistic Safety Assessment (PSA) update since it provided additional plant specific information regarding containment design and accident sequences which have the potential for bypassing containment. PSNH submitted the report to obtain staff comments on the risk perspectives suggested by the PSA update and the sensitivity study on emergency planning zone size. For several years the staff has had a policy of reviewing Probabilistic Risk Assessments for the purpose of identifying any potentially significant safety issues. Additionally, the PSA update identifies design features and accident recovery measures which have the potential for significantly reducing the radiological consequences resulting from intersystem loss of coolant accidents. In discussions with the staff, PSNH management has stated that along with other emergency planning measures being pursued, and depending on the NRC's staff technical evaluation of the emergency planning zone sensitivity study, the study could be a factor in decisions regarding emergency planning for Seabrook. Markey/NRR |