ML042720354

SECY-05-0010 - Recommended Enhancements of Emergency Preparedness and Response at Nuclear Power Plants in Post-9/11 Environment

ML042720354
Person / Time
Issue date:	01/10/2005
From:	Reyes L NRC/EDO, Office of Nuclear Security and Incident Response
To:	Commissioners NRC/OCM
Blount T NSIR/DPR 415-1501
References
NRC-2017-000314 SECY-05-0010
Download: ML042720354 (5)

Text

OFFICIAL USE ONLYOFFICIAL USE ONLYPOLICY ISSUE(Notation Vote)January 10, 2005SECY-05-0010FOR:The CommissionersFROM:Luis A. ReyesExecutive Director for Operations /RA/

SUBJECT:

RECOMMENDED ENHANCEMENTS OF EMERGENCY PREPAREDNESS ANDRESPONSE AT NUCLEAR POWER PLANTS IN POST-9/11 ENVIRONMENTPURPOSE:To obtain Commission approval of the staff's recommendations for enhancing emergencypreparedness and response in the post-9/11 environment.BACKGROUND:The basis of radiological emergency preparedness and response (EP) is to protect public healthand safety through the avoidance of radiological exposure of the public due to a release from anuclear power plant. Since the Three Mile Island (TMI) accident of 1979, the underlyingpremise has been that conditions and events driving an accident are typically due to equipmentmalfunction, component failure, or operator error. As a result, it is assumed that the event willescalate in a stepwise fashion through the event classifications (i.e., Alert to Site AreaEmergency to General Emergency) based on subsequent equipment malfunctions, componentfailures, or operator errors. Accident progression in security-based events may not be aslogical or diagnosable. However, EP is a dynamic process with flexible plans to allow forresponse to a wide range of events. CONTACT: Thomas Blount, NSIR/DPR 415-1501OFFICIAL USE ONLYMay be exempt from public release under the Freedom ofInformation Act (5 U.S.C. 552)Exemption Number_____2______Nuclear Regulatory Commission review required before publicrelease. Thomas B. Blount, EPD:DPR:NSIR Name and organization of person making determination. Date of Determination: 10/22/04 OFFICIAL USE ONLYThe Commissioners-2-OFFICIAL USE ONLYFollowing the events of September 11, 2001, the staff issued SECY-03-0165, "Evaluation ofNuclear Power Reactor Emergency Preparedness Planning Basis Adequacy in the Post-9/11Threat Environment," dated September 23, 2003. While SECY-03-0165 determined that theEP basis remains valid, the staff recognized that security events differ from accidental eventsdue to the planned action to maximize damage and loss of life. Certain EP functions, such asonsite personnel accountability or site evacuation, may not be appropriate using current EPstrategies. The staff has identified enhancements that improve the implementation ofemergency plans in response to security events. DISCUSSION:A terrorist act cannot affect core physics and cause melt sequences to occur faster or create alarger source term than those previously analyzed. However, the precursor events leading upto core damage may occur at a different pace or sequence than experienced in other events. Since issuance of SECY-03-0165, the staff identified several enhancements for emergencyplan implementation during security-based events.The staff informed stakeholders of these enhancements during regional outreach meetings(11/10/04, 12/1/04, 12/2/04 and planned for 1/13/05) and meetings with the Nuclear EnergyInstitute and industry representatives, but has not discussed implementation details. The staffrecognizes that some of the proposed enhancements affect offsite response organizationsdirectly and that further dialogue is appropriate. The staff intends to continue outreach effortsand workshops in order to ensure appropriate stakeholder involvement with the FederalEmergency Management Agency (FEMA) and State and local officials. Followingimplementation, the staff intends to continue to engage licensees and offsite responseorganizations to ensure that the enhancements were implemented appropriately and will informthe Commission of its findings in this regard.The proposed program enhancements are summarized below and are described in greaterdetail in the attachment to this document. *Enhanced Security-Based Emergency Action Levels (EALs)The staff intends to make security-based emergency declarations more anticipatory thandeclarations used for accidental events so that emergency response actions can beimplemented earlier. The staff is developing guidance with appropriate stakeholderinvolvement, consistent with the Commission's direction in staff requirements memoranda,"STAFF REQUIREMENTS - DISCUSSION OF SECURITY ISSUES (CLOSED-EX.1),9:30 A.M. WEDNESDAY, AUGUST 18, 2004," dated September 10, 2004 and "STAFFREQUIREMENTS - COMSECY-04-0019," dated May 5, 2004. This guidance will enhance thecurrent radiological event-focused scheme by improving security-based EALs. The staffintends to issue this guidance in a safeguards advisory.*Enhanced Onsite Protective ActionsOnsite protective actions are intended to maximize site personnel safety during emergencyconditions. Current practices may not be appropriate during security-based events due to thephysical danger of l and based atta cks and the short time frames that may be involved with anaircraft attack. Protective actions, such as the site evacuation and assembly, must be carriedout with consideration of the risk to personnel from the hazard. The staff supports appropriate OFFICIAL USE ONLYThe Commissioners-3-OFFICIAL USE ONLYenhancement of onsite protective actions which ameliorate the risks associated with asecurity-based event. The staff is developing guidance to assist licensees in the developmentof such enhancements. The staff intends to issue this guidance in a safeguards advisory.*Abbreviated Notification to the NRCThe current reporting requirements allow licensees up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to inform the NRC OperationsCenter of an imminent threat to the facility. In the post 9/11 environment there is a threat ofcoordinated attacks. The timing of this notification would not allow the NRC to warn othernuclear facilities of the threat or initiate a Federal response to the affected site in a timelymanner. The staff view is that it is appropriate for licensees to notify the NRC immediately after informing local law enforcement agencies (e.g. State/County/local Police or County Sheriffdepending on site specific arrangements) of the threat and requesting assistance. Thisnotification to the NRC is intended to be of short duration, containing basic information andminimum details. This supports NRC notification of other nuclear facilities and initiates Federalresponse to the affected facility. This notification may also initiate the Federal response to an"Incident of National Significance" under the National Response Plan (NRP). The staff intendsto issue this guidance in a safeguards advisory.

• Security-Based EP Drill and Exercise ProgramIn SECY-03-165, the staff advised the Commission of a plan to implement a dr ill and exerciseprogram that would have each licensee conduct site-specific enhanced security-based drills orexercises to improve emergency response organization skills. The staff intends to providelicensees the opportunity to voluntarily adopt such a program through issuance of a safeguardsadvisory. It is planned that a pilot drill program would be implemented to gather lessonslearned before demonstration drills or exercises for each site are scheduled. *Review of EP Planning Standard GuidanceThe staff intends to review the NRC guidance in NUREG-0654/FEMA-REP-1, "Criteria for thePreparation and Evaluation of Radiological Emergency Response Plans and Preparedness inSupport of Nuclear Power Plants." The review would capture the guidance provided by the staffin the security advisory proposed in this SECY as well as that promulgated by theCommission's Order of February 2002. The results of the review will be issued as asupplement to the NUREG. This review will be conducted in a manner complimentary to the"top-to-bottom" review being performed by the Emergency Preparedness Directorate of EPregulations and requirements contained in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. Should the review of guidance identify necessary regulatory changes, that information will beprovided to the top-to-bottom review team. The staff will seek stakeholder input and will coordinate with FEMA. The staff will provide theCommission with a schedule for completion of the planned "top-to-bottom" review and plannedenhancements as directed in SRM-M041214B, "STAFF REQUIREMENTS - BRIEFING ONEMERGENCY PREPAREDNESS PROGRAMS INITIATIVES, 1:00 P.M.DECEMBER 14, 2004," dated December 20, 2004.

OFFICIAL USE ONLYThe Commissioners OFFICIAL USE ONLY*Adjustment of EP Inspection ResourcesTo ensure appropriate licensee implementation of program enhancements, the staff intends tomodify the NRC EP inspection program. In the attachment, the staff describes an adaptedinspection program that will incorporate the security event based enhancements whileminimizing resource implications. *Enhanced Offsite Protective Action Recommendations (PARs)The staff proposes working with stakeholders on a safeguards advisory to operating nuclearpower plant licensees seeking voluntary adoption of enhanced offsite PARs for security events. The enhancement would have licensees consider PARs for the general public at emergencyclassification levels lower than a General Emergency. One such enhanced scheme would be:in-place sheltering for the general population and evacuation of schools and parks, within a 2-mile radius at a Site Area Emergency or lower classification. The in-place sheltering PARwould direct the general public indoors to monitor the local emergency alert system (EAS) inpreparation for an evacuation should plant conditions degrade. Stakeholder consultation onthis enhancement will involve OROs and FEMA. *Abbreviated Notification to Offsite Response OrganizationsThe staff proposes working with stakeholders on a safeguards advisory to operating nuclearpower plant licensees seeking voluntary adoption of an abbreviated initial notification to Stateand local authorities. The current practice is for licensees to provide a detailed description ofthe event with supporting information in the initial notification. The timing of some securityevents may not allow the use of this process. Stakeholder consultation on this enhancementwill involve OROs and FEMA. RECOMMENDATIONS

The staff recommends that the Commission approve the following staff activities: 1.Issuance of a safeguards advisory to licensees seeking voluntary adoption of:

• Enhanced Security-Based EALs

• Enhanced Onsite Protective Actions

• Abbreviated Notification to the NRC

• Security-Based EP Drill and Exercise Program2.Review of each of the EP planning standards guidance and development of anew supplement to NUREG-0654/FEMA-REP-1 for security events. 3. Adjustment of EP inspection resources to incorporate assessment of licenseeimplementation of the program enhancements identified in this paper.4.Development of a safeguards advisory to offsite stakeholders and FEMA seekingvoluntary adoption of:* Enhanced Offsite PARs* Abbreviated Notification to Offsite Response Organizations OFFICIAL USE ONLYThe Commissioners OFFICIAL USE ONLYRESOURCES:The activities addressed in this paper were anticipated during the creation of the EmergencyPreparedness Directorate (EPD). The staff intends to perform these activities with existingEPD allocated resources of 2.9 FTE in FY 05 and 3.3 FTE in FY 06, as identified in theattachment. The staff anticipates no resource impacts on the Regions or other NRCorganizations.COORDINATION

This paper has been coordinated with the Office of the General Counsel, which has no legalobjection. The Office of the Chief Financial Officer has reviewed this Commission Paper forresource impacts and has no objection./RA/Luis A. ReyesExecutive Director for Operations

Attachment:

Background Information in Supportof Staff Recommendations

Package: ML043090445 Commission Paper: ML042720354 Attachment ML043090281* See previous concurrence Non-Public Public Sensitive Non-SensitiveOFFICEEDP:DPR:NSIREPD:DPR:NSIREDP:DPR:NSIRD:EPD:DPR:NSIRD:IRD:DPR:NSIRNAMETBBlount*EWWeiss*TJMcGinty*(DRobertsfor)NLMamish*RHWessman*DATE3825938259382783828738293OFFICETECH EDNRR/DIPMD:DNS:NSIRD:DPR:NSIRD:PMDA:NSIRNAMEPEKleene*BABoger*GMTracy DDORMAN forEJLeeds*MLCohen*DATE11 /3/2004 11/ 5/2004383003830211 / 18/2004 OFFICEOCFOOGCOED:NRRNSIRNAMEJLFunches*(LBarnettfor via email)STreby*(NLO)CNolan* (via email)JEDyer*RPZimmerman*DATE11/24 /200411 /18/200411 /17/200411 /19 /2004 12 /14 /2004OFFICEDEDHEDONAMEWKaneLReyesDATE / /01 /10 /05 / / / / / /