ML19249E848
| ML19249E848 | |
| Person / Time | |
|---|---|
| Issue date: | 08/02/1979 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19249E813 | List: |
| References | |
| REF-10CFR9.7 SECY-79-499, NUDOCS 7910020564 | |
| Download: ML19249E848 (8) | |
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t NRR Action Plan August 2,1979 by Brian Grimes
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i NRR Action Plan "J.r..
I.
INTRODUCTION e...
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.L II.
SUMMARY
AND CONCLUSIONS III. NRR RESPONSIBILITIES RELATIVE TO EMERGENCY PREPAREDNESS NRR reviews the emergency plans submitted by the licensees according to the requirements of Appendix E to 10 CFR 50.' The Accident
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Analysis Branch, DSE, pe'rforms a review of the licensees' plans prior to issuance of an OL.
The Environmental Evaluation Branch, DOR, reviews any modifications to the emergency plans of operating reactors. Currently two professionals in AAB and one in EES are assigned to thse tasks.
IV.
CURRENT NRR PROGRAM AND CAPABILITIES
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In order to upgrade the emergency plans for all operating reactors
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and near term OL applications,' DOR has established a task force consisting of a NRR team leader, a member of the technical staff of LASL, who will provide technical assistance to NRC, and in.IE member. These teams will review the licensee's emergenci plans for compliance with Regulatory Guide 1.101 and the recommendations of the NRC/ EPA task force NUREG-0357. The review will ir..lude an on-site evaluation of the licensee's emergency planning provisions, including his interaction and coordination with local and state authorities.
The schedule for these reviews will assure completion of the review of all operating power reactors by July 1980.
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V.
NRR REOUIREMENTS AND NEEDS
%.ze A.
procram Deficiencies The primary program deficiencies are related to a lack of resources applied to the emergency preparedness area.
The principal program deficiencies identified are as follows:
1.
Existing guidance for power reactors licensee emergency plans (R.G.1.01) has not been applied to most operating nuclear power plants.
In add', ion, uniform action levels and related terminology have not been required and these have not been adequately related to plant effluent and process parameters.
2.
Instrumentation to follow the course of an accident, including wide range effluent monitors (R.G. 1.97) has not been required at all operating plants.
3.
Requirements for Emergency Operations Center with direct information from the plant control room and adequate facilities for licensee local, State and Federal representatives have not been defined and applied.
3g 4.
Offsite moniuring required of the licensee and local and State Jy authorities has not been def.ined and required.
5.
The relationship between offsite agency emerge.ncy plan and licensee-emergency plans has not been developed in te.ms of minimum requirements for licensing.
6.
While some limited excercising of individual licensee has been required and excerising of State plans has been encouraged through the Office of State Programs activities, joint exercises of licensee, local, State and Federal plans have not been required and the extent of resource mobilization required in' these exercises has not been defined.
7.
A number of regulation and regulatory guide changes have been identified as necessary and desirable which relate to the above deficiencies.
In addition, additional efforts are needed to improve NPC's information gathering capabilities during a accident including implementation of the items identified in the paper " Incident Response Center," Draft 2, July 23, 1976.
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B.
Resource Deficiencies
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Implementation of the NRR Short Term action plan will require about one million dollars.in contract assistance and reassignment of several person to act as team leaders for the team described in Section VI.
Development of long term resource requirements will await experience with the review teams but it is expected that a permanent NRR staff of 8 to 15 people will be required to review new application, keep operationg plant plans current, support standard activities, develop NRC response capabilities and participate in joint test excercises. The size of the permanent staff will depend on the continuing funding level for contractor activities.
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VI. NRR Action Plan A.
Immediate Action Plan The NRR frrrnediate action plan is described in SECY-79-450 dated July 23, 1979 which is attached for convenient reference.
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B.
Develocment of Long Range Action' Plan HRR will need to budget resources to support the following activities:
l.
Regulation and Regulatory Guide changs (SD lead) a.
Revision to August 16, 1978 proposed changes to Appendix E to reflect NUREG-0396 guidance.
b.
Revision of Appendix E to provide more specifics (parts of Regulatory Guide 1.101) in the regulations Revision of Regulatory Guide 1.101 (and p rhaps Appendix E) c.
+w provide for specific, unifom action levels based on specified plant parameters (to be developed by NRR teams).
d.
Revisien of Regulatory Guide 1.97 to reflect current efforts iE=Eh and experience gained in upcoming implementation.
Preparation of a proposed. regulation requiring concurrence in e.
State /Jocal plans as a condition for power reac'er licenses.
(including criteria for granting and withdrawing licenses and any grace periods or hearing opportunities afforded licensees /
States when licenses are threatened because of State plan problems).
(SP will provide the main input to the SD in this area).
f.
Preparation of a proposed regulation reouiring joint test exercises once each five years and within one year of initial plant operation, g.
Issuance of Revision 2 of Regulatory Guide.1.89 on qualification of equipment (has been held pending detemination of whether ECCS equipment should be qualified to TID type source term or something less).
h.
Issuance of a proposed rule or policy statement indicating what role emergency planr.ing feasibility is to play in the consideration of alternative sites in the licensing process.
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Criteria for assessment of offsite etpabilities (SP lead).
3.
NRC information gathering capability (IE lead).
NRR needs to dey41op lists of parameters and work with IE in detemining extent of real-time information display.
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PROBLEM TOPICS WITH HER LEAD AND THEIR RELATION TO NRR ACTION PLAN r
3-5 'L?.cVaf licensee authority over off-site agencies No legislative fix to give NRC or licensee authority over off-site agencies isikkely. All concerned will have to make the best of the current division
.of powers. The problems arising out of the split responsibility / authority situation will be partially solved by NRR/SP team interaction during upcoming reviews and by increased public pressures on State / local authorities to have good plans. This area is not to be specifically addressed in the NRR action plan.
B-3 Licensee planning now based primarily on design ~ basis accidents N
Need revision of August 16, 1978 proposed changes to Appendix E to reflect 4=
NUREG-0396 guidance (SD lead).
Need backfitting of Regulatory Guide 1.97
'(with any necessary revisions frem TMI lessons learned and the current short term effort to revise Regulatory Guide 1.97).
This will be done for high priority items during NRR emergency preparedness team effort and by implementation of lessons learned short term actions.
Will also need longer term effort on instrumentation to follcw the course of an accident in support of 050 revisions of Regulttery Guide 1.g7.
C-l.a Imoreve'NRC cuidance to licensees Need to elaborate on areas in Regulatory Gu#de 1.101, espec "ly with '
respect to unifom action level criteria.
This will be partly done by NRR/SP action team.s as indicated,in current action plan.
Sece followup may be needed by SD.
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'D-1 Assessment of offsite cacabilities in licensino'orecess This will be done by NRR/SP teams in cooperation with Regional Advisory C ::rtittees. Long tenn means will await experience with teams.
E-2 Expansion ~of emeroency olannino' resources Short tem solved by teams, long tem by routine budget process.
E-3 Oceratino olants.rieed to'be'eva10ated ~against current ~ criteria This will be done by team efforts under current action plan.
E-7 NRC infomation gathering capability needs imorovement NRR' needs to ' develop lists of parameters needed.
First cut in July 23, 1975
~ Incident hesponse paper. Lessons learned task force has preliminary list hh fo. r onsite. technical center.
Short tem effort (NRR/SD) to revise
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Regulatory Guide 1.97 and specify specific instruments to follow the course
'of an accident will lay useful groundwork.
IE would take lead on ccmunications and physical facilities.
F-2 Evaluation criteria for drills / exercises.
Wil be deycloped by NRR/SP. teams for joint exercises using any Sandia/SAI work available.
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July 23, 1979 SECY-79-450
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For:
The Commissioners T'hru:
Executive Director for Operations Fran:
Harold R. Denton, Director, Office of Nuclear Reactor Regulation
Subject:
ACTION PLAN FOR PROMPTLY IMPROVING EMERGDt
- PREPAREDNESS
Purpose:
To infom the' Commission of the staff's p1ans to take immediate steps tp improve licensee preparedness at all operating power plants and for near-tem OL's.
Discussion:
While the emergency plans of al1 power reactor,1,i_gensees_.
have been reviewed by the staff in the past fo'r confomance to the general provisions of Appeodix E to _10 CFR Part 50, the most recent guidance on emergency planning,.primarily that given in Regulatorf Guide 1.101 " Emergency Planning for Nuclear Powe'r Plants". has not yet been fully implemented by most reactor licensees.
Further, there are some additional areas where improvements in emergency planning have been highlighted as particularly significant by the Three Mile
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The NRR st'aff plans to undertake an intensive effort ove:r about the next year to improve licensee preparedness at all operating power reactors and those reactors scheduled for an operating license decision within the next year.
This effort will be closely coordinated with a similar effort by the Office of State Programs to improve State and 1ocal response plans through the concurrence process and Office of. Inspection and Enforcement efforts to verify proper implementation of licensee emergency preparedness activities.
The main elements of the staff effort, as listed in, are as folicws:
(1)
Upgrade licensee emergency plans to satisfy Regulatory Guide 1.101, with special attention to the development of unifom action 1evel criteria based on plant parameters.
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(2) Assure the implementation of the related recomr.enda-tions of the NRR Lessons Learned Task Forte involving instrumentation to follow the course of an accident and relate the information provided by this instrumentation to the energency plan action levels.
This will include instrumentation for post-accident sampling, high range radioactivity monitors, and improved in-plant radiciodine instrumentation. The implementation of the Lessons Learned recommendation on instrumentation ~
for detection of inadequate core cooling vdll also be factored into the emergency plan action Tevel criteria.
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(3) Determine that an Emergency Operations Center for Federal, State and local personnel has been established with suitable communications to the plant, and that upgrading of the facility in accordance with the Lessons Learned recommendation for an in-plant technical support center is underway.
(4) Assure that improved licensee offsite monitoring capabil-ities (including additional TLD's or equivalent) have been c.r.L.
provided for all sites.
~1e relationship of State / local plans to the licensee's and Federal plans so as to assure the capability to take appropriate emergency actions.
Assure that this capability will be extended to a distance of 10 miles as soon as practical, but not later than January 1,1981. This item will be performed in conjunction with the Office of State Programs and the Office of Inspection and Enforcement.
(6) Require test exercises of approved Emergency Plans (Federal, State, local, licensees), review plans for such exercises, and participate in a limited number o' joint exercises.
Tests of licensee pTans will be required to be conducted as soon as practical for all facilities and before reactor startup for new licensees.
Exercises of State plans will be performed
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The C,cmmissioners.
9=A in conjunction with the concurrence reviews of the Office o.f State Programs. Joint test exercises involving Federal, State, local and licensees will be conducted at the rate of about 10 per year, which would result in all sites being exercised once each fivr. years.
The staff review will be accomplished by~ about 6 rtview teams,usimilar to the concept used to assure s.titable implementation of the physical security provisions of 10 CFR 73.55.
As a minimum, the teams
. will consist of a team leader from NRR, a member from Lo.1 Alamos Scientific Lab (LASL) and, at least for field visits, a member from the IE Regional office.
LASL will be used as the source of non-NRC team members because of
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the expertise gained and familiarity with the plants acquired during the physical security reviews. The Division of Operating Reactors will have the responsibility for ccmple-ting these reviews for both operating reactors and near-term OL's.
J. R. Miller, Assistant Director, DOR will be respon-sible for implementatiori of the program.
General policy and technical direction will be provided by Brian Grimes, Assistant Director, 00R.
MF The.f,irst sites to be reviewed by the teams will be those scheduled for operating ~ licenses within the next year and those sites in areas of relatively high population.
Major milestones for the program are being developed and will include regional meetings with licensees to discuss the program, site visits by the review team, and meetings with 1ocal official s.
Coordination:
This action plan has been discussed with the Task Force on Emergency Planning and the Task Force Chairman, T. F. Carter, has advised that the Task Force deliberations to date have indicated no reason why NRR should not proceed.
The Office of State Programs concurs in this plan.
The Office of Inspection and Enforcement concurs in the plan.
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NRR expects to perform this task without augmentation of resources beyond those authorized for FY79 and FY80.
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Harold R. Denton, Director Office of Nuclear Reactor Regulation Enelasure:
Emergency Preparedness Improvements for Operating P1 ants and Near Tem OL's 2
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EDISTRIBUTION
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Exec Dir for Operations ACRS Secretariat 4
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ENCLOSURE NO. 1 EMERGENCY PREPARECNESS IMDROVEMENTS AND COMMITMENTS REQUIRED FOR OPERATING PLANTS AND NEAR TERM OL'S Impl ementation Item Categoryl/
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Upgrt.de emergency plans to. Regul atory Guide 1.101 A
with special attention to action level criteria based. on plant parameters.
2.
Implement certain short term actions recommended by Lessons Learned task force and use these in action level criteria.2./
2.1.8(a) Post-accident sampling Design review complete A
Preparation of revised proced'ures A
Impleme.9t plant modifications B
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2.1.8(b) High f ange radioactivity monitors B
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2.1.8(c)
Improved in-plant iodine instrumentation A
3.
Establish Emergency Operations Center for Federal, State and Local Officials (a)
Designate location and alternate location and A
provide communications to plant (b)
Upgrade Emergency Operations Center in 8
conjunction with in-piant technical support center 1/
Category A:
Implementation prior to OL or by January 1,1980 (see NURCG-0578).
Category Al:
Implementation prior to OL or by mid-Ig80.
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sa Category 3:
Implementation by January 1,1981.
3 he implementation of the Lessons Learned task force recomme[xf ation item 2.1.3 instrumentation for detection cf inadequate core cooling, will also be factored 49 into the action level criteria.
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Impl ementatton Item Catecory 4.
Improve offsite monitoring capability A
5.
Assure adequacy of State / local plans 1
(a) Against current criteria A
(b) Against upgraded criteria B
6.
Conduct test exercises (Federal, State,1 ocal,
licensee)
(a) Test of 1 fcensees emergency p1an AI (b) Test of State emergency plans Al
' (c) Joint test exercise of emergency plans (Federal, State,1 ocal,1 icensee)
New OL's B
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