Transcript Slide 1
EMERGENCY PREPAREDNESS
A VISION FOR THE FUTURE
NREP April 22, 2009
Alan Nelson
Director Emergency Preparedness
Nuclear Energy Institute
Discussion Topics
Industry’s Commitment
Nuclear Energy Institute
Regulatory Enhancements
Looking Ahead
Moving to the Future
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Nuclear Industry’s Commitment to
Emergency Preparedness
A commitment to excellence throughout
the industry coupled with continual
training, self-assessment, and testing has
produced a high level of preparedness
– Effective methods assess performance in drills and
exercises
– Lessons learned from actual events, drills, exercises, and
independent critiques
– State-of-the-art response facilities
– Communication technology are used as effective tools for
dealing with emergencies
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Historical View
Edison Electrical Institute
Atomic Industrial Forum
Nuclear Management and Resources
Council
National Radiological Preparedness
Conference
Nuclear Energy Institute
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Nuclear Energy Institute
The Washington, D.C. policy organization
of the nuclear energy industry
NEI’s MISSION
– To create favorable U.S. Energy policy for
the continued safe use of nuclear energy
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Nuclear Energy Institute
PURPOSE
Provide unified policy direction on
regulation and legislation
Represent nuclear industry before
congress, executive agencies, federal
regulatory bodies, and state policy forums
Disseminate positive information about
nuclear energy to policy-makers and the
public
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Emergency Preparedness
Essential Issue
Emergency preparedness involves
technical or operational issues of
significance that can have political and
financial impacts on all, or most of the
industry
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NEI Oversight and Support
Nuclear Strategic Issues Committee
Emergency Preparedness Working Group
Task Forces
– Draft Rulemaking
– Protective Action Strategies
– Emergency Action Levels
– Hostile Action Based Drills
– Frequently Asked Questions
– New Plant Applications
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Regulatory Enhancements
Schedule
– Federal Register
– 75 day comment period comments due
– NEI will request a longer public comment
period
– Support each of the public meetings
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NRC Specific Request for Comments
1. Inclusion of National Incident
Management System/Incident Command
System
2. Staffing and Augmentation – alternative
approach
3-5. Expand to Non-power Reactors
6. Effective date for new plant licensees
7. Implementation schedule
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Eleven Main Areas Addressed
1.
2.
3.
Licensee on-shift ERO roles and responsibilities
EALs for hostile action threat events
Alternative ERO augmentation and alternate
facilities
4. Licensee coordination with OROs
5. Protection for on-site personnel during hostile
action event
6. Conduct of security drills and exercises
7. Alert Notification System backup capabilities
8. Event identification and classification time lines
9. EOFs – performance based approach
10. Evacuation travel estimate updating
11. Emergency Plan change process
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1. On-Shift Multiple Responsibilities
NRC has been pursuing revising Table B-1 since
the mid 1990’s
Security efforts have put additional strains on
minimum shift resources
Industry Perspective
– Industry is committed to staffing our nuclear
plants consistent with the goal of nuclear safety
– Staffing requirements must be consistent with
probable outcomes and not based on a
completely unlikely scenario
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1. Impact On-Shift Multiple
Responsibilities
Licensee would have to perform a job task
analysis to determine functional
responsibilities
There is some consideration for the use of
a tabular approach that would modify the
current table B-1 in NUREG 0654/FEMAREP-1
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2. EALs for Hostile Action
Threat Events
NRC will codify requirements for existing
Emergency Action Levels that were
created based on NRC Orders to
Licensees in 2002 and 2005
Licensees and OROs have already
incorporated threat EALs into their
program
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2. Impacts EALs for Hostile Action
Threat Events
EALs in the proposed rule are already in
effect
Licensees will include security / hostile action
based events that address these EALs in
drills and exercises
FEMA should consider these EALs and
associated events in evaluating exercises
and reasonable assurance
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3. ERO Augmentation and
Alternate Facilities
Concern that during a hostile action event some
facilities such as TSC, OSC, EOF may not be
available to perform function
Solution is to require alternate facilities capable of
– Staging on site responders
– Performing off site notifications
– Repair team preparation / dispatch
Additional operational requirements may include
– Obtaining and display of key plant data
– Capability to analyze plant technical information
– Ability to provide briefings on event conditions and
prognosis to licensee and off site responders
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3. Impact Alternative ERO
Augmentation Facilities
Possible impact for extent of play and
evaluation of such capabilities
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4. Licensee Coordination with OROs
NRC will require licensees to ensure that OROs will
support and have capabilities required to respond to
hostile action events
Existing mutual aid agreements will satisfy this
requirement according to NRC presentation at RIC.
OROs already have the expected capabilities and
will demonstrate during hostile action threat drills
that will be conducted as part of 6-year exercise
cycle.
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4. Offsite Impact Coordination
with OROs
Licensees will have to evaluate ORO capabilities
related to hostile action threat response (LLEA,
traffic control, fire response, EMS, field
monitoring)
OROs may have to demonstrate existing
capabilities augmented resources of existing
capabilities procedures
FEMA expected to develop its own review
criteria which should be in NUREG 0654/FEMA
REP-1 supplement 4.
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5. Protection of On-Site Personnel
during Hostile Action Event
10 CFR 50 Appendix E Section I will
require that Licensees will have to develop
a range of protective actions for on site
personnel
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5. Impacts on Licensees and OROs
Unknown impacts until we see the NRC’s
interim staff guidance
OROs and licensees generally have existing
relationships to ensure that on site personnel
can be protected when on site security forces
are at capability limits
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6. Conduct of Security Drills
and Exercises
As part of the 6 or 8 year exercise cycle
licensee and ORO will conduct REP / hostile
action based drills/exercises
As part of drill and exercise program,
scenarios will have to encompass a wide
spectrum of events from those that
demonstrate mitigation with little or no
radiological impact to those that demonstrate
severe damage and release (typical of
current REP biennial plume exposure
exercises).
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6. Impacts on Licensees and OROs
NEI will revise NEI 06-04 to reflect lessons learned
from HAB program and request NRC endorsement
Licensees will have to develop a much larger library
of exercises with a range from little to major
consequence.
Major impact on extent of play to enable more
realistic exercise scope
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7. Alert Notification Back Up
Capabilities
Recommends amending regulations to require a
compensatory means to notify the public if the
primary system is unavailable
– Replaces concept of requiring backup power to
sirens
– Goal is to evaluate technologies and other
methods
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7. Impact Alert Notification Back Up
Capabilities
Confirmation and effectiveness of route
alerting
Anticipate that FEMA will revise REP-10
to provide for such changes and the
changes should be consistent with the
national alerting criteria being prepared by
DHS
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8. Emergency Classification Timeliness
SEC’Y attempts to codify the Performance
Indicator commitment to classify within 15 minutes
The 15 minute criteria forcing a decision could
negatively impact safety if improper classifications
are made
Industry Perspective
– Current criteria for “timely” classification is
appropriate. For the few actual events timely
should be assessed based on circumstances.
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8. Impacts on Licensees and OROs
Actual events may be complex and take
time to appropriately evaluate. The 15
minute criteria forcing a decision could
actually wind up negatively impacting
safety and possible offsite actions if
improper classifications were made
because clock ran out
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9.Performance Based
Consolidated EOFs
Establishes need to set criteria for Common fleet
EOFs and Standard Plans
Efforts now require exemption and considerable
regulatory interface
Industry Perspective
– Industry should endorse the concept for
standard criteria.
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9. Impacts on Licensees and OROs
Impact will be determined on site by site
basis
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10. Evacuation Time Estimate (ETE)
Updates
New update required if there is a + 10% change in
population of the EPZ in a year period
NRC will issue new ETE development guidance
Basis is NUREG/CR 6953 or a new guidance
document that will be issued along with the proposed
rules
Presumption is that accurate ETEs help licensees
and OROs in developing more suitable protective
action strategies, tactics and directions
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10. Impacts Evacuation Time Estimate
Updates
Impact on licensees to regularly monitor
population data and develop new ETEs
ETE experts believes 10% change is
unrealistically low
Impact on OROs – If the evaluation is
done to soon the results will have
marginal value
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11. Emergency Plan Change Process
Develop a consistent repeatable definition for
Reduction In Effectiveness (RIE)
Industry Perspective
– Strongly endorse the concept of a repeatable
consistent definition
– NRC should consider NEI proposed definition
– NEI will propose industry guidance for NRC
endorsement
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11. Impacts Emergency Plan Change
Process
Licensees may have to maintain
configuration control approach to E-plan
and EP facilities, structures, infrastructure
Licensees may maintain a configuration
control system to determine whether or
not a change in the plant affects the
emergency plan
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Concerns
We believe that there is significant
impact on FEMA and our offsite
counterparts
– NRC rulemaking cross cuts DHS and FEMA
authority – regulatory authority could cause
inconsistency and subjectivity during
evaluation:
•
•
•
•
Existing “all hazard” capabilities of OROs
Alert and Notification
ORO response capabilities
Evacuation Time Estimates
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Concerns
It’s not appropriate to address these in the
context of nuclear power plants
There are existing Presidential directives
for all hazards approaches to emergency
communications, incident management
(NIMS), and the National Exercise
Program
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Looking Ahead
Reflecting on NEI mission
NEI has identified industry subject matter experts for
each of the 11 draft rulemaking recommendations
Evaluation of each has been completed along with
bench marking a number of critical areas
Licensees should brief their offsite counterparts and
self identify areas of concern
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Looking Ahead
NEI will develop industry response
incorporating your concerns
Licensees should discuss the many
impacts of the rule with their offsite
counterparts and encourage them to
respond and attend NRC/FEMA public
meetings
NEI will attend each of the NRC/FEMA
public meetings
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Hostile Action-Based Drills
Open Forum Session
April 23, 2009 1:00 to 4:45 pm
Improving Coordinated Stakeholder
Response Through Discussion of
Preparation Techniques and Key
Observations
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Moving to the Future
Marty Hug
Sr Project Manager Emergency Preparedness
Nuclear Energy Institute
Phone: (202) 739-8129
Mobile: (202) 439-0768
Email: [email protected]
Sue Perkins-Grew
Sr. Project Manager
Nuclear Energy Institute
phone: 603.773.7278
mobile: 202.247.8163
email: [email protected]
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