ML19106A143
| ML19106A143 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/2019 |
| From: | Office of Nuclear Security and Incident Response |
| To: | |
| Shared Package | |
| ML19106A141 | List: |
| References | |
| Download: ML19106A143 (72) | |
Text
Part 3: EP Regulations and Guidance
EP Regulations Title 10, Code of Federal Regulations, Part 50
-- the 16 planning standards
10 CFR 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities
- Contains requirements for emergency plans for all applications under Part 50 and Part 52
- Binding on license applicants and licensees
- Contains the requirements for emergency plans for non-power reactors
- Contains supporting requirements for the planning standards in §50.47(b) for power reactors
- Emergency plans are a part of power reactor applicants Final Safety Analysis Report (FSAR), Chapter 13
- Examples
- Requires the capability to notify State and local authorities within 15 minutes of emergency declaration
- Defines equipment and facility needs
- Defines exercise and training expectations 3
LO 10 & 11,
Planning Standards 10 CFR 50.47(b)
The onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards:
(1)Responsibilities assigned (9)Accident assessment (2)Onsite ERO* (10)Protective actions (3)Emer. Response support (11)Radiation exposure control (4)Emer. Classification scheme (12)Medical & health support (5)Notification Methods (13)Recovery and Reentry (6)Emer. Communications (14)Exercises & Drills (7)Public education & info (15)Training (8)Emergency facilities (16)Plan maintenance
- FEMA 44 CFR 350.5 has a nearly identical set of planning standards.
Direct relationship with NUREG-0654 (1=A, 2=B, etc.)
4 LO 4 & 5
Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the EPZs have been assigned, emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
- Translated:
- Responsibilities for onsite/offsite personnel/organizations are established to support 24/7 coverage
- Examples:
- Emergency response organizational chart
- Position descriptions
On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support are specified.
- Translated:
- Transition from normal duties to emergency responsibilities; ensuring sufficient on-shift emergency staff at all times; timely augmentation of on-shift staff; and identifying offsite emergency resources
- Examples:
- Shift Manager becomes Emergency Director
- Licensee Table B-1
- Identify offsite response entities to respond onsite such as local ambulance agency(s), fire department(s), police, hospital(s), etc., and obtain MOUs
Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensees near-site EOF have been made, and other organizations capable of augmenting the planned response have been identified.
- Translated:
- Federal, State, and local governmental assistance is arranged with space available in EOF for their response and other technical organizations as needed by the plan
- Examples:
INPO State Officials Utility Owners Group Local Officials Coast Guard Federal Officials
A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
- Translated:
- Ability to classify an emergency via a standard scheme
- Examples:
- Emergency Action Levels
- ORO Standard Operating Plans (SOPs) entry conditions
Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations and the public have been established; and the means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ have been established.
- Translated:
- Capability to provide notification and response instructions to onsite/offsite emergency response personnel and the public.
- Examples:
- Call out list
- Notification Forms
- EAS Messages
- Alert and Notification Systems ANS)
Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public
- Translated:
- Have plans for contacting all necessary OROs and emergency personnel
- Examples:
- Pagers, Cell Phones, Blackberries
- NRC Emergency Notification System
- Direct ringdown phones from licensee to counties/States
- WebEOC'
Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency, the principal points of contact with the news media for dissemination of information during an emergency are established in advance, and procedures for coordinated dissemination of information to the public are established.
- Translated:
- Information on nuclear power plant emergencies shall be provided annually to the general public and the media
- Examples:
- JICs
- Phone Books
- Annual Mailers, Calendars
- Annual Media Training
Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
- Translated:
- Provide and maintain all facilities and equipment necessary to support emergency response at all times.
- Examples:
- TSC, OSC, EOF, Backup EOF, JICs
- Air Samplers, Computers,
- Emergency Kits (survey equipment and supplies, personnel protective equipment)
- Onsite & Offsite Monitoring Systems
Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
- Translated:
- Ability to monitor and assess radiological release
- Examples:
- Dose modeling software
- Core damage estimation tools
- Field monitoring
- Correlations of plant parameters to source term of releases
A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering and as a supplement to these, the prophylactic use of potassium iodide as appropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
- Translation:
- Have a set of preplanned protective actions (that must consider evacuation and sheltering - potassium iodide is a possible supplement, but not a replacement) that can be implemented based on radiological conditions for both EPZs
- Examples:
- Develop guidelines, strategies, and means for implementing a range of PARs for both plant personnel and the public
- Evacuation sector maps
- Onsite Assembly Areas
- List of Dairy Farms within 50 miles
Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.
- Translated:
- Have a plan for protecting and directing plant personnel that must respond to radiological hazards during an emergency and base it on the EPA guidance
- Examples:
- Provisions for authorizing and control radiation exposures greater than occupational limits in support of response actions
- Lifesaving actions
- Emergency worker dosimetry both onsite and offsite
- Decontamination facilities
Arrangements are made for medical services for contaminated injured individuals.
- Translated:
- Arrangements made with ambulance and hospitals responsible for contaminated injured personnel
- Arrangements made for evaluating and treating radiation overexposures
- Examples:
- Evaluated drills with ambulance and hospital personnel
- Onsite emergency medical squads
General plans for recovery and reentry are developed.
- Translated:
- Create a framework for recovering from an emergency
- Examples:
- Event termination and/or de-escalation criterion pre-established in the emergency plan
Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
- Translated:
- Evaluated and training exercises/drills are conducted to identify and correct weaknesses and maintain proficiency
- Examples:
- Onsite ERO drills
- Biennial Evaluated Exercise (FEMA)
- Licensed Operator Requal (LOR) Drills
- Fire Drills
- Critiques
Radiological emergency response training is provided to those who may be called on to assist in an emergency.
- Translated:
- Training to onsite and offsite emergency response personnel
- Examples:
- Fire department training on decontamination efforts
- Classroom training on classifying emergencies
Responsibilities for plan development and review and for distribution of emergency plans are established and planners are properly trained.
- Translation:
- An emergency planning department is established with qualified personnel
- Examples:
- Initial and continuous training of EP department staff
- Annual review of emergency plan
Realism Rule What happens if a State or local government refuses to participate in emergency planning?
- Provides means for an applicant to obtain a license when State or local governments decline or fail to participate adequately in offsite emergency planning
- Applicant/licensee may:
- Demonstrate that deficiencies in emergency plans are not significant
- Show that adequate interim compensatory actions have been or will be taken promptly
- Assert that other compelling reasons exist that would permit plant operations
- §50.54 contains requirements that are conditions in every power reactor operating license.
- §50.54(q) addresses the licensees Emergency Plan
- Licensees are required to follow and maintain the effectiveness of emergency plans which meet the requirements in Appendix E, and for power reactors, the planning standards of §50.47(b)
- Allows licensees to make changes to their emergency plan without prior Commission approval as long as it does not represent a Reduction in Effectiveness (RIE) of the plan and the plan continues to meet the requirements in Appendix E, and for power reactors, the planning standards of
§50.47(b)
- Changes that do not meet these criteria must be submitted for prior NRC review as a license amendment
- Most EP violations are cited against §50.54(q) 22
- Requires licensees provide for the development, revision, implementation and maintenance of its EP program
- Requires a periodic review of all program elements of the licensees EP program by persons having no direct responsibility for implementation of EP Program, including:
- Evaluation of adequacy of interfaces with State and local governments
- Evaluation of licensees drills and exercises and emergency response capabilities and procedures
- Results of review and recommendations are documented, reported to corporate and plant management, and retained for 5 year period
- Portion of report addressing onsite-offsite interfaces is made available to State and local governments 23
- Licensee notifications to NRC regarding EP
- Notify the NRC immediately following notification of State and local agencies and not later than one hour after declaration of any of the emergency classes
- Activate the ERDS as soon as possible and not later than one hour following declaration of an Alert or higher emergency class
- Make immediate follow-up notifications as conditions change or new data becomes available; maintain open communication channel upon request by the NRC.
- EP related non-emergency eight hour report: 10 CFR 50.72(b)(3)(xiii)
- Any event that results in a major loss of emergency assessment capability, offsite response capability, or offsite communications capability (e.g.,
significant portion of control room indication, ENS, or offsite notification system).
24
End of Regulations
- Now for guidance on how to meet the regulations
NUREG-0396 (EPA 520/1-78-016)
Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants
- Joint NRC/EPA Task Force formed in 1976
- Issued December 1978
- Determined the appropriate degree of emergency response planning efforts around nuclear power plants
- Introduced Generic Emergency Planning Zones (EPZs) concept as basis for planning of response actions
- Provides basis for federal/State/local government emergency response 26
NUREG-0654/FEMA-REP-1 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants
- Product of a joint NRC/FEMA Steering Committee
- Guidance and criteria for satisfying 10 CFR 50.47(b) and Appendix E
- NRC has endorsed NUREG-0654 to be an acceptable approach to complying with the regulations, e.g., guidance
- FEMA incorporated NUREG-0654 by reference into 44 CFR 350
- Generic, systematic approach to EALs
- Organized to link back to the regulations
- Revision 2 in progress 27 LO 3
NUREG-0654/FEMA-REP-1
- Section I - Planning Basis
- Section II - Planning Standards & Evaluation Criteria
- Elements A - P
NUREG-0654/FEMA-REP-1
- Appendix 1 - Emergency Action Levels
- Appendix 2 - Meteorological Criteria
- Appendix 3 - Alert and Notification
- Appendix 4 - Evacuation Time Estimates
- Appendix 5 - Glossary
- Supplement 1 - Criteria for Utility Offsite Planning
- Supplement 2 - Early Site Permit
- Supplement 3 - Guidance for Protective Action Strategies
- Addenda - 2002, Replace Outdated Citations
- Supplement 4: Criteria for National Preparedness Initiative Integration, Exercise Enhancement, and Backup Alert and Notification Systems
NUREG-0696 Functional Criteria for Emergency Response Facilities
- February 1981
- Safety Parameter Data System (SPDS)
- Guidance on emergency response facility design, location, functions, capabilities
- Control Room (during an emergency)
- Technical Support Center (TSC)
- On-Site Operations Center (OSC)
- Emergency Operations Facility (EOF)
- Integrated support to the Control Room
- Updated in NSIR/DPR-ISG-01
EAL Scheme Guidance
- NUREG-0654 Appendix 1, Emergency Action Level Guidelines for Nuclear Power Plants
- NUMARC/NESP-007, A Methodology for Development of Emergency Action Levels
- NEI 99-01, Methodology for Development of Emergency Action Levels
- Added EALs for permanently shutdown reactors and dry cask spent fuel storage
- Improvements to NUMARC/NESP-007
- NEI-07-01, Rev. 0, "Methodology for Development of Emergency Action Levels Advanced Passive Light Water Reactors
- Developed for AP-1000 and ESBWR reactors
- Cannot mix methodologies
- Any one scheme must be based solely on the one guidance document.
31
Regulatory Guide 1.101 Emergency Planning and Preparedness in Support of Nuclear Power Reactors Issued to provide an acceptable method for licensee compliance with regulations for the content of emergency plans
- Revision 1 (1977)
- Criteria for plans to cope with emergencies and serious accidents emphasized need for procedures to implement drills and exercises
- Revision 2 (1981)
- Endorsed NUREG-0654/FEMA-REP-1
- Revision 3 (1992)
- Endorsed NUMARC/NESP-007, Methodology for Development of EALs
- Could use either 0654 or 007, but not portions of both
Regulatory Guide 1.101 (continued)
- Revision 4 (2003)
- Endorsed NEI 99-01, Methodology for Development of EALs
- RIS 2003-18 issued to describe EAL change approval process
- Revision 5 (2005)
- Provides guidance for co-located licensees
- Draft guidance for co-located licensees
- Revision 6
- In process, will document approval of NEI 99-01 Revision 5, as well as NEI 07-01 for the AP1000 and ESBWR designs
- Will also provide a resource for all current generic communications and guidance related to emergency plan development and maintenance
Somewhat New & Updated Guidance
- NSIR/DPR-ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants
- NSIR/DPR-ISG-02, Interim Staff Guidance Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants
- NUREG-0654/FEMA-REP-1 Supplement 3, Guidance for Protective Action Strategies
- NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies
- Regulatory Guide 1.219, Guidance on Making Changes to Emergency Response Plans for Nuclear Power Reactors
Other NUREGs
- Developing an Emergency Risk Communication (ERC)/Joint Information Center (JIC) Plan for a Radiological Emergency
- Guidance on Developing Effective Radiological Risk Communication Messages: Effective Message Mapping and Risk Communication with the Public in Nuclear Plant Emergency Planning Zones
- NUREG-0737, Supp. 1
- Clarification of TMI Action Plan Requirements
Generic Communications
- Interim Staff Guidance
- Regulatory Guide
- Bulletin
- Information Notice
- Regulatory Issue Summary
- 10 CFR 50.54(f) letter
- A complete list of EP-related generic communications can be found at:
NUREG Functions
- Public outreach information
- Regulatory support
- Technical analyses and research results
- Action plans and guidance
- Generic technical issue resolution
- Team reports
- Other agency administrative information
NUREG Types
- Publications prepared by NRC Example: NUREG-0696
- Brochures prepared by NRC staff Example: NUREG/BR-0314
- Conference proceedings prepared by NRC or contractors Example: NUREG/CP-XXXX
- Publications prepared by NRC contractors Example: NUREG/CR-7002
- Publications resulting from international agreements Example: NUREG/IA-XXXX
NUREG Uses
- NRC staff guidance and instructions
- Licensing action procedures and acceptance criteria
- Staff suggested course of action
- Not a substitute for regulations
- No compliance required
- Licensees may propose alternatives
Interim Staff Guidance (ISG)
- Fills the gap between revisions
- Not a substitute for regulations
- No compliance required
- Licensees may propose alternatives
Regulatory Guide (RG)
- 1. Power reactors 6. Products
- 2. Research and test 7. Transportation reactors 8. Occupational health
- 3. Fuels and materials 9. Antitrust and facilities financial review
- 4. Environmental and 10. General siting
- 5. Materials and plant protection
RG Functions
- Acceptable methods to implement regulations
- Evaluation techniques for specific problems or postulated accidents
- Contains data required for reviewing permit and license applications
- Not substitute for regulations
- No compliance required
- Licensees may propose alternatives
Bulletin Types
- Addresses significant and urgent issues in safety, security, or safeguards
- Urgent compensatory actions
Bulletin Functions
- May request actions, information, analyses, or new / revised commitments
- May NOT request long term actions
- May NOT require actions or commitments
Bulletin 2005-02:
Emergency Preparedness and Response Actions for Security-Based Events
- Security based classifications
- Prompt notification of NRC
- Onsite protective measures
- Emergency Response Organization (ERO) augmentation
- Drill emergency response capabilities
Information Notice (IN)
- Recently identified significant operating experience (OE)
- Recently completed research results
- Licensees evaluate information notices for applicability
- IN 2005-19, Effect of Plant Configuration Changes on the Emergency Plan
Regulatory Issue Summary (RIS)
- Includes a broad range of subjects with generic applicability
- Does not involve a request for action or information unless it is voluntary
RIS Functions
- Informs licensees of technical or policy positions not previously communicated or fully understood
- Reports NRC endorsement of industry developed documents
- Solicit voluntary pilot program participation
- Informs licensees of regulatory relief opportunities
- Announces regulatory documents issuance
- Requests voluntary submittal of information for NRC administration of regulatory process
The licensee shall at any time before expiration of the license, upon request of the Commission, submit, as specified in § 50.4, written statements, signed under oath or affirmation, to enable the Commission to determine whether or not the license should be modified, suspended, or revoked. Except for information sought to verify licensee compliance with the current licensing basis for that facility, the NRC must prepare the reason or reasons for each information request prior to issuance to ensure that the burden to be imposed on respondents is justified in view of the potential safety significance of the issue to be addressed in the requested information.
Each such justification provided for an evaluation performed by the NRC staff must be approved by the Executive Director for Operations or his or her designee prior to issuance of the request.
10 CFR 50.54(f) Letter Highlights
- Licensees submitted written statements enabling the Commission to determine if the license should be modified, suspended, or revoked
- NRC will prepare reasons for each information request, making sure that the burden is justified
- Each justification must be approved by the Executive Director for Operations
EP Document Cheat Sheet
- Commissions EP Regulations in 10 CFR Part 50
- Must be complied with, unless exempted
- Regulatory Guides
- Provides acceptable method for complying with a particular regulation(s);
licensee can propose alternative
- A staff or contractor prepared technical report
- May be endorsed in a regulatory guide as an acceptable method for complying with regulations
- Generic Letters
- Topic specific, licensee action required
- Bulletins, Regulatory Issue Summaries, Information Notices
- Topic specific information, licensee action not required 51
CFR Generic Letters -
Topic specific, must be complied with Regulatory Guide - Endorsement of = guidance acceptable for all licensee NUREGs - Acceptable method to comply with regulation on case by case basis 52
EP Inspection Program and Enforcement
Topics:
- ROP Framework
- EP Performance Indicators
- EP Baseline Inspection Program
Reactor Oversight Process
- Replaced old Systematic Assessment of Licensing Performance (SALP) Process
- Risk-Informed Inspection and Oversight
- Provides tools for inspecting and assessing licensee performance
- Maintains safety
- Increases openness
- More effective, efficient, and realistic
- Reduces unnecessary regulatory burden
- Uses Performance Indicator System
- Three Key Strategic Areas
- Reactor Safety
- Radiation Safety
- Safeguards
- Each Area has cornerstones
- Occupational Radiation Safety
- Security
Performance Assessment Safety Cornerstones Baseline Inspection Performance Indicator Results Results Significance Significance Determination Process (SDP) Threshold Action Matrix Special Inspections Regulatory Response
Significance Levels
- Green Very low safety significance (licensee response band)
- White Low to moderate safety significance (increased regulatory response band)
- Yellow Substantial safety significance (required regulatory response band)
- Red High safety significance (unacceptable performance band)
Emergency Preparedness Cornerstone
- 3 Performance Indicators
- Baseline Inspection Program 59
Performance Indicators
- Drill and Exercise Performance (DEP)
- Emergency Response Organization Drill Participation (ERO)
- Alert and Notification System Performance (ANS)
Drill and Exercise Performance (DEP) PI
- Monitors timely and accurate licensee performance in drills and exercise when presented with opportunities for classification, notification, and protective action recommendations (PARs)
- 90% Green/White threshold
- of timely & accurate classifications, notifications & PARs (calculated over previous 8 quarters)
- of total opportunities
DEP PI Example Emergency Response Organization (ERO) PI
- Percentage of ERO members assigned to fill key positions who have participated in a performance-enhancing drill/exercise
- 80% Green/White threshold
- of ERO members assigned to fill key positions that have participated in a drill (calculated over 8 quarters) total number of key positions assigned to ERO members
ERO PI Example Alert & Notification System (ANS) PI
- Monitors the reliability of offsite ANS
- Periodic tests are the regularly scheduled tests (documented in the licensees test plan or guidelines) that are conducted to actually test the ability of the sirens to perform their function (e.g., silent, growl, siren sound test).
- 94% Green/White threshold
- of successful siren tests (calculated over 4 quarters)
- of total number of siren tests
ANS PI Example Baseline Inspections
- IP 71114 Attachments .01 - .08
- Exercise Evaluation (biennial exercise)
- Alert and Notification System Testing
- Emergency Response Organization Augmentation
- Emergency Action Levels And Plan Changes
- Maintenance of Emergency Preparedness
- Drill Evaluation (resident inspector)
- Exercise Evaluation (hostile action)
- Scenario Evaluation
Significance Determination Process
- Precepts
- EP is a defense-in-depth measure
- Emergency Plan being implemented in response to event (probability of event is 1.0)
- EP SDP makes a qualitative predictive evaluation of the impact of the finding on the licensees capability to implement its E-plan should an accident occur
- Risk to public health and safety increased due to lack of fully functioning defense-in-depth feature
Two Entry Conditions
- Failure to Comply An EP program is noncompliant with a regulatory requirement (e.g., 16 planning standard, Appendix E)
- Associated with preparedness findings rather than response findings
- Typically identified during routine program inspections
- Failure to Implement A finding during an actual event in which a failure to comply precluded effective implementation of program elements
- Associated with response findings rather than preparedness findings
Risk Significant Planning Standards (RSPSs)
- Origins of the RSPSs
- During the development of the EP Cornerstone, the most risk-significant EP elements were identified as being distinct from other EP elements
- Developed by a group of EP subject matter experts, including NRC staff and industry stakeholders, with input from members of the public
- EP SDP methodology recognizes findings in the identified risk-significant elements as being more significant
- Classification - (b)(4); Emergency Action Level Classification Scheme
- Notification - (b)(5); Prompt notification of offsite officials and the public
- Dose Assessment - (b)(9); Dose assessment capabilities
- Protective Action Recommendations - (b)(10); Range of protective actions for 10 mile EPZ
End Part 3 Contact Information
- Office: (301) 287-3756
- email: robert.kahler@nrc.gov