ML20149J741

Speech Entitled, Status & Prospectus for Emergency Preparedness Reviews at Nuclear Power Reactors, to Be Presented at 830920 AIF Conference in New Orleans,La

ML20149J741
Person / Time
Issue date:	09/20/1983
From:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
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ML20149B526	List: IA-87-743, Forwards Transcript of Presentation at State Liaison Officers 831206 Meeting,Including Questions Received from States.Appreciation for Participation in Meeting Expressed ML20149J714 ML20149J741 ML20149J851 ML20149J863
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FOIA-87-743 NUDOCS 8802230198
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JORbAN SP&cC#

EP STATUS AND PROSPECTUS I

FOR EMERGENCY PREPAREDNESS REVIFWS AT NUCLEAR POWER REACTORS Edward L. Jordan, Director Division of Emergency Preparedness I and Engineering Response Office of Inspection and Enforcement l

U.S. Nuclear Regulatory Comission l Washington, D.C. 20555 Aw Confersnet S<ph 20 s MU h o rle4 %

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l The purpose of my presentation is to describe the NRC programs of emergency  ;

preparedness review and give you my views on changes witch are under consid- l l eration. I believe dustry and State, local, and Federal organizations have  ;

come a long waylin i roving emergency preparedness within and near nuclear ,

power plants in a relatively short time. These improvements include development of detailed procedures, training of personnel and improved response capabilities.

It is generally recognized these improvements have been difficult and have come at great expense. The regulated community has expressed concerns that regulators have translated certain guidance into requirements and in some cases the guidance has changed much too rapidly. For the foreseeable future, the existing structure for emergency preparedness is expected to be stable. The NRC staff has been instructed to effect improvements in regulations and guidance while assuring l stability to the regulated comunity. Lf that sounds ambiguous I hope that the

further discussions will remove any concerns. My discussion of changes, which i are under consideration, does not anticipate a major source term change. Most i of you are aware that the NRC has a program office established to review the

! source term from severe accidents which now targets the issuance of a report of

! its findings in the sunspr of 1984. I personally don't anticipate major changes

, in emergency preparedness programs as a result of refinements in source term.

The NRC has a longer term study underway on severe accidents. Results of this I study are presently targeted to be issued in 1985. Present indications from that l study cause one to have to do very detailed studies for each plant to come up with useful changes in probability and/or consequences of severe accidents. The more likely outcome is improvements in certain plants or classes of plants.

A brief review of the history of current emergency planning efforts reflects I that in early 1976 the NRC received a request from the Conference of Radiation Y Control Program Directors, an organization of State officials, to make a deter-mination of the most severe accident basis for which radiological emergency response plans should be developed by offsite agencies. In response to this request, a Joint Task Force consisting of members from the Nuclear Regulatory Comission and the Environmental Protection Agency was established in Novesiber 1976 to address emergency planning issues at and around cossnercial nuclear power reactor sites. After two years of study the Task Force prepared a report entitled "Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants "

NUREG-0396, EPA 520/1-78-016, which was published for public comment in the Federal Register on December 15, 1978. The coment period was extoded after the TM! accident in March 1979 to incorporate additional public view subsequent to the accident.

The major recomunendation of the report was that two Emergency Planning Zones (EPZs-) should be established around light water nuclear power t.lants. The EPZ '

for airborne exposure should have a radius of about 10 miles; the EPZ for contam-inate'd food should have a radius of about 50 miles. Predetermined 1rotective action plans should be provided for the EPZs. The exact size and siape of each EPZ should be decided by emergency planning officials after they consider the specific conditions at each site. .

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2-The NRC published in the Federal Register on October 23, 1979 a policy statemenc that the NRC endorsed for use the guidance contained in the Task Force report. ,

The Comission 4trected its staff to incorporate the planning basis guidance into existing documents used in the evaluation of State and local emergency response plans to the extent practicable.

Also, the EPA published in the Federal Register on January 15, 1980 a policy statement that EPA endorsed for use the guidance contained in the Task Force report and it would be EPA's policy to incorporate the reconsnendations of the Task Force into all EPA emergency response guidance to State and local officials.

As a result of the accident at Three Mile Island (TMI), it was concluded that onsite and offsite emergency preparedness upgrades were needed to protact the health and safety of the public in addition to upgrades in certain engineered safety features and management of operations. The Federal Emergency Management Agency (FEMA) was assigned lead responsibility for offsite emergency preparedness around nuclear facilitigs by Presidential directive in December 1979. The NRC and FEMA established a framework of cooperation in radiological emergency response '

planniq matters expressed as a Memorandum of Understanding (M00), dated Novemc r 4,1980, so that mutual efforts would be directed toward more effective plans and related preparedness measures at and in the vicinity of nuclear facil-ities. AccoMing to the MOU, FEMA coordinates all Federal emergency planning and responsa, and makes findings and determinations as to the adequacy of offsite plans and whether these plans are capable of being implemented, and makes those findings and determinations available to NRC. The NRC utilizes the FEMA findings I

and determinations for the purpose of making determinations on the overall state of emergency preparedness.

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In recognition of the need for more effective emergency planning and preparedness expressed by the NRC/ EPA Task Force and evaluations of TMI emergency response, the NRC amended its regvlations on emergency preparedness planning in order to assure that adequate protective measures can and will be taken in the event of a radiological emergency. The final rule, effective November 3,1980, specified that an applicant for, or a holder of an operating license was required to submit plans covering onsite and offsite emergency preparedness. The NRC would determine whether the onsite and offsite emergency plans provide reasonable assurance that appropriate protective measures can and will be taken in the event of a radio-logical emergency. A significant feature of the rule on emergency planning was the incorporation of the Emergency Planning Zones (EPIs) recoomended by the NRC/ EPA Task Force.

Additionally, the final rule specified 16 emergency planning standards for ontite and offsite emergency organizations within the Emergency Planning Zones. Guldince on im'plementation of these planning standards is contained principally in NUREG-0654/ FEMA-REP-1 Rev.1, which was developed jointly by the NRC and FEMA.

This document provides a comon reference and guidance source for NRC Licensees, Federal, State and local governments to develop radiological emergency plans and 4

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improve emergency preparedness. This guidance was developed within the framework of an NRC/ FEMA $teering Comittee, which was established to coordinate the agencies' effort in upgrading emergency preparcdness. The interim version of this document was published in January 1980, and subjected to public coment under Federal Register Notice 44 FR 9768 of February 13, 1980. Based upon the comments received, meetings with the Interorganizational Advisory Comittee (made up of State and local representatives) rnd later at a September 1980 Workshop sponsored by FEMA for State officials, the final version was prepared for publication and use in November 1980.

A major effort undertaken by the NRC was the Emergency Prepat dness Appraisals conducted during April 1981 to April 1982. This program was directed toward evaluating the capabilities and performance at all operating reactors and identifying major deficiencies, rather than identifying non-ccepliance.

Currently about 20 State site specific plans and approximately 50 local government plans for offsite emerggncy response have beer, fonnally approved by FEMA under their proposed emergency radiclogical plans and preparedness Rule 44 CFR 350.

Considerable media attention has been directed toward deficiencies identified at licensed facilities. Thus far, these deficiencies have been resolvable with some difficulty. No significant delays have occurred in the issuance of an operating license because of offsite emergency preparedness issues. In general, delays which have been encountered in the area of offsite emergency preparedness

), can be attributed to problems which have occured in the development of local

emergency plans and, to a lesser extent, State site specific plans. While there are several reasons for this occurence, the fundamental underlying cause has been a direct result of the expansion of the planning effort to encompass the 10 mile plume Emergency Planning Zone. This has significantly increased the number of local governments involved in radiologic'al emergency planning to the level where there are now over 1,000 counties / parishes involved. Many of these counties / parishes lack the resources and technical expertise to undertake the task of developing energency plans and this has consequently strained the resources of State governments and other bodies relied upon for assistance. In most cases, the utilisies have provided financial and technical assistance.

Utilities, in general, have had a difficult time in fully satisfying the requirement for establishing an Alert and Notification System. Many licensees were unable to meet the initial deadline of July 1,1981, because of problems associated with the design, procurement and installation of siren systems. As a result, the July 1,1981 date was extended to February 1,1982. Notices of viola' tion were issued to operating reactor licensees who failed to install and initially test a prompt notification system by the new deadline. To date, all licensees are in compliance with this part of the revised rule. The final adequacy test of the systems has yet to be done. Fonnal evaluation of the systems will be scheduled in the future based on finalizatior, of FEMA's "Standard Review Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants."

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Under the revised rule, full-scale exercises were conducted at all operating power reactor sites during the period between April 1981 and April 1982. In l addition, most 6f the second round of exercise has been completed and a third annual exercise has been completed at some sites. Where deficiencies have been

! identified in the onsite plans, corrective steps have been taken. In addition

( to exercises, the readiness of State, local and utility emergency organizations to carry out effective response measures has also been demonstrated by the

! response to ac'ual emergencies which have occured during the past two years

! including the steam generator tube rupture at Ginna on January 25, 1982 and the potential ficoding of the Dresden plant on December 3,1982.

The requirements and guidance for Emergency Response Facilities (ERFs) were stabilized in Supplement 1 to NUREG-0737 and this guidance was comunicated via regional seminars in February 1983. These requirements and guidance are not expected to change. The NRC has reviewed the licensees submittals regcrding EOF j habitability and location. In some cases, licensees did not meet the guidance I

with regard to location of the primary and/or backup EOF, and requested exceptions l

from the Comission. These exceptions are being reviewed on a case-by-case basis.

l NRC review is not a prerequisite for implementation. Staff review will be in the fortn of an audit of the Licensee's implementation through an appraisal program.

A pilot appraisal is currently scheduled for late October 1983. The purpose of l

this pilot appraisal, is to evaluate the appraisal procedures, methods, and i documentation as well as manpower needs and impact on the Licensee. The proposed l implementation of the ERF appraisal program is scheduled to begin in March 1984.

I Ii Confidence has also been gained that emergency organizations will carry out their responsibilities by observing the actions of response personnel in non-l radiological accidents involving toxic and hazardous materials. Recent examples have been the evacuatiun of 17,000 psrsons, due to a chemical explosion and fire in Taft, Louisiana, and the evacuation of 5,000 Denver residents because of a nitric acid spill. In the Louisiana accident which occured two miles from a nuclear plant under construction (Waterford-3), local emergency response officials

credited the developmer.t of emergency plans for the nuclear plant with their l success in handling the chemical emergency.

. As previously stated, the NRC staff has been instructed to effect improvements l in regulations and guidance while assuring stability to the regulated comunity.

l The NRC staff is currently reviewing the emergency planning regulations to make changes to correct problems and to clariff the original intent of a particular regulation. After three years experience in implementing the regulations as well as additional insight gained through exercises and research in the portrayal of reactor risk since 1980, the s9ff believes that while the conclusions reached in 1980 are still valid, some refinement of the regulations are in order.. An example of some preliminary findings of this review are as follows:

1. The gradation in risk tnat exists within the 10 mile radius EPZ warrants a l

predation in response. This gradation was recognized in NUREG-0396 and i ,

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the need for clarification has been shown in hearings and exercises. As an example, prompt actions within about two miles and vectored actions in a sector of 2 to 10 miles is a much more probable response to a severe accident than evacuation of an entire 10 mile radiue EPZ.

2. Elimination of the "Unusual Events" as an emergency class as these events do not affect the public heslth and safety and are unlikely to "run up" in severity. There are approximately 200 events per year which meet the criteria for an "Unusual Event." Experience has shown that the more significant events are recognized directly.

3. Clarify the intent of the 4 month clock rule to specifically state that the deficiencies in planning may be given 4 months for correction, whereas deficiencies in implementation will be handled as a normal enforcement action.

AdditionH1y, a Joint NRC/ FEMA Working Group has been established to review and assess toe criteria in RUREG-0654/ FEMA-REP-1 Rev. I to determine where changes should be made to correct problem areas and to clarify the intent of the guidance criteria. Pre'liminary findings of this review indicate that revisions should be made in several areas to ensure consistency with the regulations and clarify ambiguities leading to misinterpretation of the guidance criteria. For example, Emergency Action Levels should lead to the proper classification of the emergency.

The emergency class triggers the initiation of emergency response, including

. offsite dose projections and notifications. With regard to notifications, the

? guidance in NUREG-0654 should specifically address the requirements of the Y regulations and provide criteria that specifies what is required to demonstrate these capabilities, l

in recent months various groups have petitioned the NRC to take emergency and remedial action against the continued operation or licensing of several power reactors, mostly in the northeast where the reactors are located near highly

! populated areas. The petitions have dealt mainly with alleged inadequacies in local plans (size of plume EPZ, public infonnation and education program, evacuation plans, etc.) or the absence of local plans (Shoreham). In one instance (Indian Point), the FEMA findings of inadequacy due to non-participation by the county in a full-scale exercise caused the NRC to invoke the four-month corrective action time period. On June 9,1983, the NRC Comissioners approved the continued operation of Indian Point, based on FEMA's supplementary report that substantial progress had been made.

In sumary, while the revised rule on emergency planning has resulted in complex problems in the integration of licensee, State and local plans it has forced the utilities to work closer than ever before with State and local emergency response organizations. It has forced everybody to speak the same language and has resulted in a much higher state of emergency preparedness than that which existed prior to early 1979. Because of concerns expressed by industry and based on experience l .

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j . l in applying guidance and in implementing the regulations, revised guidance regarding EOFs was issued in February of this year and revisions to the regulations and guidance ark underway in this and other areas.

In discussions with representatives of other agencies and industry two factors {

are evident. Improvements are needed promptly but any major change could ,

interrupt forward motion. I again assure you of stability in the NRC programs for emergency planning. I, like you, am closely following the developments in the source term and severe accident research programs but I am not tempering any actions in anticipation of reduced accident consequences. A real state of emergency preparedness requires a management conmitment, application of scarce resources and close and patient coordination with appropriate State and local organizations and federal agencies. An opportunity to demonstrate the reasure of cooperation which has developed is provided by a full-field exercise scheduled for March 1984 at the St. Lucie Facility. This is the first exercise involving full participation by Federal agencies which will test the integrated response capabilities and provide an evaluation of the total emergency preparedness effort.

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d STATUS AND PROSPECTUS FOR -

EMERGENCY PREPAREDNESS

. SIGNIFICANT IMPROVEMENTS IN SHORT TIME BY INDUSTRY AND NRC

. PROCEDURE DEVELOPMENT TRAINING

. RESPONSE CAP 4BILIT1ES

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PROBLEMS WITH EMERGEplCY PREPAREDNESS UPGRADE i

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. BACKFITTING i

. STAFFING  !

. FA.CILIT1ES AND EQ'UIPMENT

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CONT'D PROBLEMS WITH EMERGENCY PREPAREDNESS UPGRADE

. INDUSTRY CONCERNS

. AMBIGUITIES IN GUIDANCE .

AND REQUIREMENTS

. TRANSLATING GUIDANCE INTO REQUIREMENTS

. CHANGES IN GUIDANCE AND REQUIREMENTS

CONT'D PROBLEMS WITH EMERGENCY ._

PREPARED. NESS UPGRADE

. EOF GUIDANCE / REQUIREMENTS i

. SUPPLEMENT 1 TO NUREG 0737 REGIONALSEMINARSf(FEB-83)

{ . THIS GUIDANCE / REQ,UIREMENTS I

i ARE'NOT EXPECTED TO CHANGE

. POST IMPLEMENTATION ~ REVIEWS

. FUNCTIONAL APPROA,CH

. REASONABLE a

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HISTORY OF CURRENT l

EMERGENCY PLANNING EFFORTS i

. . NRC/ EPA TASK FORCE 1976

. DRAFT REPORT FOR COMMENT -

1978

. COMMENT PERIOD EXTENDED ~ TO INCORPORATE PUBLIC VIEWS AFTER TMI ACCIDENT INTRODUCTION OF EMERGENCY PLANNING ZONES (EPZs)

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CO.N T ' D

) HISTORY OF CURRENT EMERGENGY PLANNING EFF0RTS, i l

. FEMA ASSIGNED LEAD F0R OFFSITE (PRESTDENT1.AL ORDER ;1979)

! . NRC/ FEMA MOU l

. FEMA C0 ORDINATES FEDERAL PLANNI.NG AND RESPONSE I

. . MAKES FINDINGS ON ADEQUACY OF 0FFSITE PLANS

. NRC UTILIZES FEMA FINDINGS TO DETERMINE OVERALL STATE OF EMERGENCY PREPAREDNESS .

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HISTORY OF CURRENT '~

I EMERGENCY PLANNING EFFORTS I

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. AMEND EMERGENCY PLANNING

) REGULATIONS -

NOVEMBER 1980 l . INCORPORATION OF EPZs'

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. ALERT AND NOTIFICATIOjN SYSTEM i

. FEMA REVIEW 0F 0FFSITE PLANS i

. EMERGENCY OPERATIONSIFACILITY 4

. FULL-SCALE JOINT EMERGENCY EXERCISE

. 16 PLANNING STANDARDS-i

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CONT'D

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HISTORY OF CURRENT EMERGENCY PLANNING EFFORTS l

l. . NRC/ FEMA GUIDANCE

. DRAFT PUBLISHED FOR COMMENT JANUARY -

1980

. WORKSHOPS FOR STATE OFFICIALS i - -

SEPTEMBER -

1980

. PUBLISHED FOR USE NOVEMBER -

1980 J

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EMERGENCY PLANNING IMPROVEMENTS --

REVIEW AND REFINEMENTS TO

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REGULATIONS

. EXERCISE FREQUENCY

. GRADAT10N IN RISK AND. RESPONSE'

! FOR 10 MILE EPZ

. ELIMI NATION OF "UNUSU AL EVENTS"

) EMERdENCY CLASS

!. . CLARIF1.CATlON OF 4-MONTH CL0CK j RULE j

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CURRENT MiSPERCEPTION .

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EMERGENCY PLANNING IMPROVEMENTS

. NRC/ FEMA STEERING COMMITjTEE

. REVIEW AND UPDATE MEMORANDUM 0F UNDERSTANDING J f . NRC/ FEMA WORKING GROUP l REVIEWANDEVALUATIONlOFGUIDANCE NUREG-0654/ FEMA-RE'?-1, REV. 1 1

! . ASSESSMENT TO DETERMINE IF, AND WHERE CHANGES SHOULD BE MADE 9

. CORRECT PRO.BLEM AREAS

. CLARIFY AMBIGUITIES 9

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SUMMARY

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l . COOPERATI VE EFFORT BETWEEN UTILI TI ES I AND STATE AND LOCAL EMERGENCY

RESPONSE ORGANIZATIONS l . OVERALL STATE OF EMERGENCY PREPAREDNESS i IMPROVED SINCE 1979 .

. NRC REVIEWING REGULATORY REQUIREMENTS AND GUIDANCE FOR REFINEMENTS AND NECESSARY CHANGES

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Date ROUTING AND TRANSMITTAL SLIP 7/29/83 To: (Name, omce symbol. room number, Inttlets Date Dullding, Nency/fost)

1. DARRELL EISENHUT 6. R0GER BLOND

2. RALPH CARUS 0

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s. MAL ERNST Action File Note arst Retum Approval For Clearance Per Conv ersation g' Prepare Reply

• As Requested For Correction Circulate CFor Your triformation See Me f  ;

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Comment Coordination investigate Jusilfy sJgnature j RDAARKS

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99 Attached is the paper for Governor Cuomo's Shoreham oq ,

i i Comission that I prepared for Bill Dircks to transmit.

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DO NoT use this form as a RECORD of approvsts, concurrences, disposals, i

clearances, and similar actions FROM: (Name. org. symbof, 4ency/ Post) Room NJ.---Bldg.

266 PHIL I

Frank Rowsome, AD/T: DST:NRR rhone no.

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