10 CFR 50.72(b)(3)(xiii), Loss of Emergency Preparedness

Loss of Emergency Preparedness

If not reported under 10 CFR 50.72(a), (b)(1), or (b)(2), an ENS notification is required under 10 CFR 50.72(b)(3) (an 8-hour report) for a major loss of emergency assessment, offsite response, or offsite communications capability. The loss of emergency preparedness capabilities should be apparent at the time of occurrence or discovery. Therefore, if all events are reported properly, it is expected that all reports under 10 CFR 50.72 are as a result of an ongoing condition.

• More nuanced endorsed by NRC: NEI 13-01, Reportable Action Levels for Loss of Emergency Preparedness Capabilities

Discussion

This reporting requirement pertains to events that would result in a major loss of emergency assessment capability, offsite response capability, or offsite communications capabilities. The loss of these capabilities could substantially impair a licensee’s, or offsite officials’, ability to respond to an emergency if one were to occur or has occurred. The focus of this reporting requirement is in the loss of capabilities to perform functions identified in the respective emergency plan. Failures of individual systems or facilities that comprise these capabilities are reportable only to the extent that these failures meet the above threshold.

Notifying the NRC of these events permits the NRC to consider implementing compensatory measures and to more completely assess the consequences of such a loss should it occur during an accident or emergency. The following are examples of equipment or facilities that may be encompassed by this reporting requirement:

• Emergency Assessment Capabilities

– safety parameter display system (SPDS)

– primary emergency response facilities (ERFs)

– plant monitors necessary for accident assessment

• Offsite Response Capabilities

– public prompt notification system(s) including sirens (primary system)

• Offsite Communication Capabilities

– ENS

– other emergency communications facilities and equipment used between the licensee’s onsite and offsite ERFs, and between the licensee and offsite officials

Losses of the above equipment and other situations should be evaluated for reportability as discussed below.

Loss of Emergency Assessment Capability

A major loss of emergency assessment capability includes those events that would significantly impair the licensee’s emergency assessment capability if an emergency were to occur. Some engineering judgment is needed to determine the significance of the loss of particular equipment. For example, the loss of the SPDS alone may not need to be reported, but a loss of the SPDS concurrent with other plant indicators or annunciators being unavailable is reportable if the licensee would be unable to assess or monitor an accident or transient in progress. Examples of events that should be evaluated against this threshold for reportability include, but are not limited to:

• A loss of a significant portion of control room indication, including annunciators or monitors, or the loss of all plant vent stack radiation monitors, should be evaluated for reportability. In evaluating the reportability of such events, only those display systems, indicators, and annunciators that are relied upon in the emergency plan and the emergency plan implementing procedures addressing classification, assessment, or protective actions; or relied upon in other station procedures that provide input to these activities need to be considered. The indication remaining available should be considered in determining if a major loss of emergency assessment capability has occurred.
• A significant degradation in the licensee’s ability to perform accident assessment functions assigned to a licensee primary ERF by the emergency plan. Typically, these functions would be the technical support center (TSC) but may include the emergency operations facility (EOF). Degradations would not be reportable if the ERF’s assessment capabilities were restored to service within the facility activation times specified in the emergency plan. Planned maintenance which impacts the accident assessment functions of the ERF, or its supporting systems, need not be reported if (1) the ERF’s assessment capabilities could be restored to service within the facility acitivation time specified in the emergency plan in the event of an accident or the

licensee had implemented viable compensatory actions, and (2) the planned outage is not expected to, and subsequently did not, exceed 72 hours.

Loss of Offsite Response Capability

A major loss of offsite response capability includes those events that would significantly impair the ability of the licensee or offsite officials to implement the functions of their respective emergency plans if an emergency were to occur. Examples of events that should be evaluated against this threshold for reportability include, but are not limited to:

• The occurrence of a significant natural hazard (e.g., earthquake, hurricane, tornado, flood, major winter storms) or other event that would do one or both of the following:

- Prevent State and local jurisdictions from maintaining evacuation routes passable, or from maintaining other parts of the response infrastructure available, to the extent that these jurisdictions would be unable to implement the public protective measures called for in their emergency plan, if known by the licensee, or,

– Restrict access to the licensee’s site, or its offsite primary EOFs, such that the licensee would not be able to augment its on-shift staff or activate its ERFs as required by the emergency plan. Offsite response support relied upon in the emergency plan, such as fire departments, local law enforcement, and ambulance services, would not be able to access the site.

Traffic impediments, such as fog, snow, and ice, should generally not be reported if they are within the respective capabilities of the licensee, State, or local officials to resolve or mitigate. Rather, the reporting requirement is intended to apply to more significant cases, such as the conditions around the Turkey Point plant after Hurricane Andrew struck in 1992 or the conditions around the Cooper station during the Midwest floods of 1993.

• Failures in the primary public alerting systems (e.g., sirens, tone alert radios), for whatever reason, that result in the loss of the capability to alert a large segment of the population in the emergency planning zone (EPZ) for more than 1 hour. The licensee should take reasonable measures to remain informed of the status of the primary public alerting system, regardless of who maintains the system, and must notify the NRC if the established thresholds are exceeded. A planned outage of the primary public alerting system need not be reported if (1) the licensee had arranged for the implementation of Federal Emergency Management Agency (FEMA)-approved backup alerting methods should public alerting become necessary, and (2) the planned outage is not expected to, and subsequently did not, exceed 24 hours.

Loss of Communications Capability

A major loss of communications capability include those events that would significantly impair the ability of the licensee to implement the functions of its emergency plans if an emergency were to occur. Failures of individual communications systems are reportable only to the extent that these failures meet this threshold. The failure of a single communication system need not be reported if there are viable alternative methods of communicating information about the emergency.

This reporting requirement only addresses those communication systems that enable a licensee to make notifications and provide followup information to Federal, State, and local officials located offsite. It also includes communication capabilities between the site and licensee ERO personnel assigned offsite. Examples of communication systems whose failures should be evaluated against the above threshold for reportability include, but are not limited to, the following:

• ERDS
• ENS
• health physics network (HPN)
• other offsite communication systems, including the following:

– dedicated telephone communication link to State or local officials

– dedicated voice and data links between the site and emergency offsite response facilities

– licensee radio system for communicating with offsite field monitoring teams

– commercial telephone lines that are relied upon for use in emergency response

Each site’s communications system will be different, and the significance of the loss of any one communication system may differ from site to site. This reporting requirement is intended to apply to serious conditions during which the telecommunications system can no longer fulfill the communications requirements of the emergency plan.

Planned maintenance that impacts the emergency communications capability need not be reported if (1) the communication system could be restored to service promptly in the event of an accident or the licensee had implemented viable compensatory actions, 13 and (2) the planned outage is not expected to, and subsequently did not, exceed 72 hours.

Although a notification may not be required under 10 CFR 50.72(b)(3(xiii) in the event of a loss of the ENS, HPN, or ERDS because of the availability of viable alternative communication means, the licensee should inform the NRC Operations Center of any failure of these systems so that the NRC may arrange for repair of NRC-supplied communications equipment. When informing the NRC Operations Center, licensees should use the commercial telephone number 301-816-5100. If the Operations Center (or the ERDS Data Center) notifies the licensee that an ENS, HPN, or ERDS line is out of service, there is no need for an additional call. At the time the failure is reported, the licensee should be prepared to supply the following information to expedite repair: (1) name of contact at location of failure, (2) commercial phone number of contact, (3) location of contact (i.e., street address, building number, room number, etc., and (4) any other information that would expedite repair.

Examples

(1) Loss of Public Prompt Notification System

The NRC has not established a numerical threshold (e.g., number, percentage, or area of failed sirens) for this reporting requirement because the thresholds need to be specific to the particular EPZ. The NRC expects its licensees to establish thresholds that reflect the EPZ-specific population density and distribution, the locations of the sirens or other alerting devices, and the overlap in coverage of adjacent sirens. For example, a loss of 10 percent of the sirens in a high-density population area may have greater impact than 13 “Promptly” means within the emergency plan requirements specified for the communication system. A loss of the ability to make initial notifications would need to be restored within 15 minutes, while a loss of the ability to communicate between ERFs would need to be restored within the facility activation time. A “viable” compensatory action is one that (1) can restore the required function in a reasonably comparable manner, and (2) is proceduralized prior to the event.

50 percent of the sirens lost in a low-density area. Similarly, a loss of 10 percent of the sirens dispersed across the entire EPZ may not be as significant as losing the same number of sirens in a single jurisdiction. As such, notifications of the loss of the primary public prompt notification system will vary according to the licensee’s “major loss” threshold. Previous notifications have included the following:

• 12 of 40 county alert sirens were disabled because of loss of power as a result of

severe weather

• 28 of 54 alert sirens were reported out of service as a result of a local ice storm
• all offsite emergency sirens were:

– found out of service during a monthly test

– taken out of service for repair

– out of service because control panel power was lost

– out of service because the county radio transmitter failed

Failures in the primary public alerting systems (e.g., sirens, tone alert radios), for whatever reason, that result in the loss of the capability to alert a large segment of the population in the EPZ for more than 1 hour should be reported as a major loss of offsite response capability. However, a planned outage need not be reported if (1) the licensee had arranged for the implementation of FEMA-approved backup alerting methods should public alerting become necessary, and (2) the planned outage is not expected to, and subsequently did not, exceed 24 hours. No LER is required because there are no corresponding 10 CFR 50.73 requirements.

(2) Loss of ENS and Commercial Telephone System

The licensee determined that ENS and commercial telecommunications capability was lost to the control room when a fiber optic cable was severed during maintenance. A communications link was established and maintained between the site and the load dispatcher via microwave transmission. Both the ENS and commercial communications capability were restored approximately 90 minutes later.

An ENS notification is required because of the major loss of communications capability.

Although the microwave link to the site was established and maintained during the telephone outage, the link would not allow direct communication between the NRC and the control room, and therefore, this in itself does not fully compensate for the loss of communication that would be required in the event of an emergency at the plant. No LER is required because there are no corresponding 10 CFR 50.73 requirements.

(3) Loss of Direct Communication Line to Police

The licensee determined that the direct telephone line to the State Police had been out of service. In this example, no ENS notification is required because commercial telephone lines to the State Police were available. An ENS notification would be required if the loss of the direct telephone line(s) to various police, local, or State emergency or regulatory agencies is not compensated for by other readily available offsite communications systems. No LER is required because there are no corresponding 10 CFR 50.73 requirements.

(4) Loss of the Emergency Response Data System

The licensee determined that the ERDS was out of service due to a failure of licensee-owned and -maintained equipment. However, the ENS was available. Because the ERDS is identified as a supplement to the ENS in Appendix E of 10 CFR 50, the failure of the ERDS does not constitute a major loss of offsite communication capability provided that the ENS is available and, as a result, no report under this reporting criterion is required. If, however, the failure is determined to be in NRC-maintained equipment, the licensee should inform the ERDS help desk of the outage so that the NRC can arrange for repair