Information Notice 2005-06, Failure to Maintain Alert and Notification System One Alert Radio Capability
| ML050680335 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/2005 |
| From: | Hiland P NRC/NRR/DIPM/IROB |
| To: | |
| Stehen F. LaVie, NSIR, 301-415-1081 | |
| References | |
| IN-05-006 | |
| Download: ML050680335 (6) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
March 30, 2005
NRC INFORMATION NOTICE 2005-06:
FAILURE TO MAINTAIN ALERT AND
NOTIFICATION SYSTEM TONE ALERT RADIO
CAPABILITY
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to inform
addressees of inspection findings concerning a licensees capability to alert members of the
public within the emergency planning zone (EPZ) in the event of a radiological emergency.
This information notice is intended to ensure that licensees using tone alert radios (TARs)
maintain positive control over the distribution of the TARs. The NRC expects recipients to
review the information for applicability to their facilities and consider taking actions to avoid
similar problems. However, suggestions contained in this information notice do not constitute
NRC requirements; therefore, no specific action or written response is required.
DESCRIPTION OF CIRCUMSTANCES
The Federal Emergency Management Agency (FEMA) approved alert and notification
system (ANS) design report for the Arkansas Nuclear One (ANO) facility stated that new
residents in the plume exposure EPZ would be identified through electric service
connection reports from utilities serving the EPZ. The residents identified would be
contacted and offered a free TAR. In practice, the connection reports were provided to
the Arkansas Department of Health, Office of Nuclear Planning and Response
Programs (NPRP). NPRP compared these reports with a TAR distribution list to identify
addresses that had not received a TAR. Letters were then sent to the new addresses
informing the resident of the availability of an emergency information booklet (EIB) and
their eligibility to receive a TAR if they were unable to hear a warning siren. When one
of the participating utilities could no longer provide the new connection reports, ANO
and NPRP agreed that receipt of the reports was not required and that letters would no
longer be sent to new residents. Thus, NPRP and ANO relied on new residents learning
of the EIB and the TARs through passive distribution at public locations, annual mass
mailing of the EIB, and periodic public service TV and radio announcements. New
residents were not directly contacted.
As a result of these program changes, ANO could no longer demonstrate a best effort
to place TARs at affected residences because the State or the licensee were no longer
identifying these residences. The NRC asked FEMA to evaluate whether the current
practice was acceptable. FEMA concluded that the program change was a loss of
administrative control of TARs and that it was questionable whether affected populations
could be notified in a timely manner. During inspection activities, the NRC determined
that the issue did not represent a degradation in the risk-significant planning standard
10 CFR 50.47(b)(5) and assigned a green finding. The NRC based this determination
on FEMAs conclusion that the automatic route alerting provided for in existing county
emergency procedures would have been capable of accomplishing the ANS function in
the entire EPZ in a timely manner.
At the Callaway Plant, TARs are used as the primary ANS for residences located
outside of the coverage area of fixed sirens. On a monthly basis, licensee clerical
personnel review new electric service hookups and disconnect information provided by
the three utilities that supply residential electric service within the plume exposure EPZ.
The database of residences assigned TARs is updated and a mailing is prepared for the
newly identified TAR residences. Licensee personnel annually request an updated
customer service list from one of the three utilities to compare with the TAR database
and the database is updated as needed. Following this update, new batteries and
instructions are sent to each residence in the TAR database.
During a scheduled monthly surveillance, licensee personnel noted an abnormally high
number of new service connections. After comparing these new connections to the TAR
database, the licensee identified 65 residences that should have been previously
identified and added to the database. The licensee determined that clerical personnel
had been told the majority of the customers are within siren coverage for newly
connected residences reported by one of the three utilities serving the EPZ. As a result, new customers for that utility were not identified as candidates to receive TARs. The
spike in new service connections occurred when the utility transferred part of its service
area to one of the other two utilities serving the EPZ. The receiving utility submitted new
connection reports on the transferred customers. Further review of the database
identified an additional 33 affected residences. Ninety-eight residences outside the
siren coverage area were not identified in the TAR database and would not have
received an emergency alerting signal in the event of an emergency at the Callaway
plant. The licensee had identified errors in the TAR database 4 years earlier but the
corrective actions taken failed to update the database and failed to implement
programmatic changes to prevent further errors. The failure of the licensees self- assessments, quality assurance audits, and supervisory oversight to identify this
problem earlier is a significant weakness in the problem identification and resolution
cross-cutting area. The NRC determined that the inspection finding represented a
degradation in the risk-significant planning standard 10 CFR 50.47(b)(5) and assigned a
white finding. A supplemental inspection was conducted. *
The FEMA ANS design report for the Wolf Creek Generating Station (WCGS)
committed the licensee to offer TARs to residences located outside of the 70 db siren
coverage area. This was an over-commitment in that the applicable standard was 60 db
for areas where the population density was less than 2000 persons per square mile.
The licensee delegated the issuance and tracking of TARs to the county emergency
preparedness office. The county emergency preparedness office received information
concerning new residents and offered TARs to them. The annual letter sent to the
populace within the EPZ provided direction that residents not having TARs and living
outside of certain named towns should contact the county emergency preparedness
office to receive a TAR.
As a result of a quality assurance audit, the licensee identified 72 residences located
outside of the 70 db siren coverage area but inside a town that would not have received
an emergency alerting signal in the event of an emergency at WCGS. The licensee
determined that the apparent cause of the weakness was the poor quality of siren
coverage maps that made it difficult for the county emergency preparedness office to
identify the location of residents in comparison to the 70 db siren coverage map. In
addition, the 72 residences needing TARs were within four of the towns that had been
identified in the annual letter as not needing TARs. The NRC asked FEMA to evaluate
whether the licensee was in compliance with the commitments in the ANS design report.
FEMA concluded that the licensee was not in compliance with the FEMA-approved ANS
design report since TARs were not offered to some residences outside of the 70 db
siren coverage area. The NRC concluded that the licensees failure to identify
residences outside siren coverage areas affected the risk-significant planning standard
10 CFR 50.47(b)(5). The NRC determined that the inspection finding did not represent
a degradation in the risk-significant planning standard 10 CFR 50.47(b)(5) and assigned
a green finding. The NRC based this determination on the fact that, although WCGS
ANS design report called for TARs outside the 70 db siren coverage area, all of the
residences were within the 60 db siren coverage area and would have been alerted in
the event of an actual emergency.
The Vermont Yankee Nuclear Power Station (VYNPS) ANS design report included fixed
sirens and TARs. TARs are the primary means of notification for several communities in
Vermont, New Hampshire, and Massachusetts. A small number of TARs are the
primary means of notification in areas in other communities outside of the coverage area
of fixed sirens. In addition, TARs are available on request to members of the public in
areas where fixed sirens are the primary means of notification. About 5000 TARs are
issued in the VYNPS EPZ. The licensee should have maintained a list of TAR users
and a list of residences who refused TARs. Although the licensee has overall
responsibility for the ANS, local officials in each community distribute the TARs to the
appropriate residences. The ANS design report approval letter states that residences
receiving TARs sign a three-part equipment loan agreement. The licensee should have
used its copy of the forms to maintain a computer list of TAR holders; the list should
have identified the residences that refused the TARs. During an inspection, the NRC determined that the list of TAR holders was not current
and that a list of the residences that refused a TAR did not exist. A comparison of the
TAR list and the 2000 census data suggests that at least 5 percent of the population in
the EPZ may have been without a TAR, may not have had the opportunity to refuse one, and would not have received an emergency alerting signal in the event of an emergency
at VYNPS plant. Although new residents may have become aware of the TARs via the
annual public information calendar and other means such as welcome letters, town
office displays, and town meetings, the approach is not consistent with a best-effort
attempt to place receivers as expected by FEMA. The NRC determined that the issue
represented a degradation in the risk-significant planning standard 10 CFR 50.47(b)(5)
and assigned a white finding.
BACKGROUND
Title 10, Code of Federal Regulations, Paragraph 50.54(q) requires nuclear power plant
licensees to follow and maintain in effect emergency plans that meet the standards in
10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. Planning standard
10 CFR50.47(b)(5) states that procedures have been established for notification, by the
licensee, of State and local response organizations and for notification of emergency response
personnel by all organizations; the content of initial and followup messages to response
organizations and the public has been established; and means to provide early notification and
clear instruction to the populace within the plume exposure pathway EPZ have been
established.
These requirements are amplified in Appendix 3 of NUREG-0654 FEMA-REP-1, Criteria for
Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in
Support of Nuclear Power Plants that states: 1) NRC and FEMA recognize that the
responsibility for activating the prompt notification system . . . is properly the responsibility of the
State and local governments. NRC and FEMA also recognize that the responsibility for
demonstrating that such a system is in place rests with the facility licensee. 2) Within the plume
exposure EPZ, the system shall provide an alerting signal and notification by commercial
broadcast (e.g., Emergency Broadcast System) plus special systems such as the National
Oceanic and Atmospheric Administration radio. A system which expects the recipient to turn on
a radio receiver without being alerted . . . is not acceptable.
The ANS provides for the timely notification of the affected population within the plume
exposure pathway EPZ surrounding nuclear power reactor sites. The ANS alerts the public of
the emergency and provides a means for public officials to distribute emergency instructions
and advisories. The ANS may be a combination of fixed or mobile sirens, TARs, automatic
telephone dialers, commercial broadcast media, and the Emergency Broadcast System.
Information Notice 2002-25, Challenges to Licensees Ability to Provide Prompt Public
Notification and Information During an Emergency Preparedness Event, addressed challenges
related to the ANS, including failure to test and maintain personal home alert devices.
DISCUSSION
FEMA advises the NRC on the status of offsite emergency planning, including the acceptability
of the ANS. FEMA bases its finding of acceptability on the licensees ANS design report and
FEMA-REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power
Plants. The NRC relies on FEMAs assessment of the licensee commitments in the facility
ANS design report in finding that planning standard 10 CFR50.47(b)(5) has been met.
FEMA-REP 10, recognizing that absolute control of TARs is forfeited once they are given to the
public, establishes a minimum distribution and maintenance program to ensure that affected
residences are offered the opportunity to obtain a TAR. The FEMA guidance states: TARs
should be offered to the public in a geographical area (where needed) and a best-effort
attempt must be made to place the radios. A record system (register) containing an accurate
list of addresses (names are optional) must be maintained for those geographical areas using
the tone alert radios. The addresses of residents refusing tone alert radios should also be
noted.
Since FEMAs determination that the ANS is acceptable is based, in part, on commitments
made by the licensee in the facility ANS design report, the NRC expects licensees to ensure
that these ANS program commitments continue to be met. Licensees are reminded that, pursuant to 44 CFR 350, significant changes to an ANS requires FEMA review and acceptance
prior to implementation.
CONTACT
S
This information notice does not require any action or written response. Please direct any
questions about this matter to the technical contact(s) listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) Project Manager.
/RA/
Patrick L. Hiland, Chief
Reactor Operations Branch
Division of Inspection Program Management
Office of Nuclear Reactor Regulation
Technical Contacts:
Stephen F. LaVie, NSIR
Robert E. Kahler, NSIR
(301) 415-1081
(301) 415-2992 E-mail: sfl@nrc.gov
E-mail: rek@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
DISCUSSION
FEMA advises the NRC on the status of offsite emergency planning, including the acceptability
of the ANS. FEMA bases its finding of acceptability on the licensees ANS design report and
FEMA-REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power
Plants. The NRC relies on FEMAs assessment of the licensee commitments in the facility
ANS design report in finding that planning standard 10 CFR50.47(b)(5) has been met.
FEMA-REP 10, recognizing that absolute control of TARs is forfeited once they are given to the
public, establishes a minimum distribution and maintenance program to ensure that affected
residences are offered the opportunity to obtain a TAR. The FEMA guidance states: TARs
should be offered to the public in a geographical area (where needed) and a best-effort
attempt must be made to place the radios. A record system (register) containing an accurate
list of addresses (names are optional) must be maintained for those geographical areas using
the tone alert radios. The addresses of residents refusing tone alert radios should also be
noted.
Since FEMAs determination that the ANS is acceptable is based, in part, on commitments
made by the licensee in the facility ANS design report, the NRC expects licensees to ensure
that these ANS program commitments continue to be met. Licensees are reminded that, pursuant to 44 CFR 350, significant changes to an ANS requires FEMA review and acceptance
prior to implementation.
CONTACT
S
This information notice does not require any action or written response. Please direct any
questions about this matter to the technical contact(s) listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) Project Manager.
/RA/
Patrick L. Hiland, Chief
Reactor Operations Branch
Division of Inspection Program Management
Office of Nuclear Reactor Regulation
Technical Contacts:
Stephen F. LaVie, NSIR
Robert E. Kahler, NSIR
(301) 415-1081
(301) 415-2992 E-mail: sfl@nrc.gov
E-mail: rek@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
DISTRIBUTION:
IN Folder
ADAMS ACCESSION NO.:ML050680335 *Concur Via E-mail
DOCUMENT NAME: G:\\DIPM\\OES\\Staff Folders\\Kramer\\TARsIN.2.wpd
OFFICE
NSIR:EPD
TECH EDITOR
TL:NSIR:EPD
SC:NSIR:EPD
D:NSIR:EPD
NAME
SLaVie
PKleene
RKahler
AMcMurtray
NMamish
DATE
03/10/2005
03/08/2005
03/14/2005
03/18/2005
03/18/2005 OFFICE
D:NSIR:DPR
OES:IROB:DIPM
CALLAWAY PM
NAME
ELeeds
JGKramer
- via e-mail
- via e-mail
- via e-mail
DATE
03/25/2005
03/08/2005
03/15/2005
03/16/2005
03/16/2005 OFFICE
A:SC:OES:IROB:DIPM
C:IROB:DIPM
NAME
- via e-mail
EJBenner
PLHiland
DATE
03/16/2005
0325/2005
03/30/2005 OFFICIAL RECORD COPY