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SU.S.NRCUnited States Nuclear Regulatory Commission
Protecting People and the Environment
Information Briefing on
Emergency Preparedness
May 3, 2011
Evolution of NRC EmergencyPreparedness Regulations
" Emergency Planning Basis
" Pre-Three Mile Island
" Post-Three Mile Island
* State/Local Participation
* Post-September 11, 2001
2
EP Rulemaking Process
too
Draft PreliminaryRule and Technical
Basis Development
Proposed Rule and DraftGuidance Development
CommentResolution Final Rule to
Commission
Draft Preliminary Proposed Rule and Final RuleRule Language Draft Guidance Published and Guidance
Issued (Public Comments PublishedAccepted for 150 days)
3
EP Rulemaking Topics
1 Amended Emergency Plan Change Process
2 Evacuation Time Estimate Updating
3 Licensee Coordination with Offsite Response Organizations*
4 On-Shift Staffing Analysis*
5 Emergency Action Levels for Hostile Action*
6 Emergency Declaration Timeliness
7 Alert and Notification System Backup Means
8 Emergency Operations Facility - Performance-Based Approach
9 Emergency Response Organization Augmentation at Alternative Facility*
10 Challenging Drills and Exercises*
11 Protection for Onsite Personnel*
12 Removal of Completed One-Time Requirements
(*) Indicates Security-Related EP Topic
4
NRC Guidance Documents
" NUREG/CR-7002
" Regulatory Guide 1.219
* NSIR/DPR-ISG-01
5
Public Comments
" Emergency Plan Change Process
" Evacuation Time EstimateUpdates
o Licensee Identification of OffsiteSupport
6
Public Comments (Continued)
" On-Shift Staffing Analysis
" Alert and Notification SystemBackup Means
" Exercise Cycles and Variations
7
Implementation Considerations
" Alignment with FEMA
" Cumulative Effects of Regulation
" Implementation Periods
" Implementation Workshops
" Follow-Up Inspection
8
AcronymslAbbreviations*ACRS
*ANS
* CFR
*EP
* EPA
" EPZ
" ERO
" ETE
* FEMA
Advisory Committee onReactor Safeguards
alert and notification system
Code of Federal Regulations
emergency preparedness
Environmental ProtectionAgency
emergency planning zone
emergency responseorganization
evacuation time estimate
Federal EmergencyManagement Agency
• FOF force-on-force
*ISG Interim Staff Guidance
*NEI Nuclear Energy Institute
•NGO non-governmentalorganization
*NRC Nuclear RegulatoryCommission
*PNREP National RadiologicalEmergency Preparedness
oSRM staff requirementsmemorandum
OTMI Three Mile Island
9
Backup Slides
10
EP Rule Implementation DatesOROP6ftD MI iUL-E' rK~LE FiiAL#ý RULE4 U~bTE lREVISEDAFNAL RULE-`
#~ EPU RUET~,IPEE TOIPEENTATION STAKEHOLD~ER IMPLEMENTATION4____________ PERIOD (2009)ERLETOI M EMITAiN(09 PERIOD (2010) INPUT (2010) PERIOD L(2011)
, Amended 30 days after date of 30 days after date ofI Emergency Plan final rule publication in 12 months final rule publication in 90 days None
• Change Process Federal Register Federal Register
Within 365 days of the Within 365 days of the later
Evacuation Time 6 months after date of later of the availability of the availability of2 final rule publication in 12 months of decennial census 12 months•,'i Estimate Updating• decennial census data or
Federal Register data or effective date effective date of final rule
of final rule
Licensee 6 months after date of 365 days after date of
Coordination with final rule publication in 24 months final rule publication in Up to 36 months 30 of from e! Offsite Response date of final rule•'• rgniaton Federal Register Federal Register•!iOrganizations
365 days from effective dateof final rule to perform
O 6 months after date of 180 days after date of staffing analysis, then 304O Stalys n final rule publication in 36 months final rule publication in 36 months days to implement interim< Federal Register Federal Register comp. measures and 24
months to complete long-
term corrective actions
Emergency Action 6 months after date of 180 days after date of 180 days from effective date5 Levels for Hostile final rule publication in 36 months final rule publication in 36 months of final rule
• Action Federal Register Federal Register
11
EP Rule Implementation DatesPROPOS,#D RULE 9W FIAL RULE' U AED REVISED FINAL -RULE
# EP RULE TOPIC; IMPLEMENTATION NPT O9 IMPLEMENTA'TION STKHLE MPEETTO
_________ PERIOD (2009) PERIOD (2010)~ INPUT ý(2O10) ~ PERIODp(2O114)~
Emergency 6 months after date of 180 days after date of6• 180 days from effective date•6) Declaration final rule publication in 12 months final rule publication in 12 months of final rule
• Timeliness Federal Register Federal Register
1) For a site with existingFEMA-approved ANS backupmeans in ANS design report,12 months from effective date
of final rule to implement ANSbackup means2) For a site at which anupdated ANS design report
1St biennial exercise would be submitted for FEMAAlert and 1st biennial exercise approval, 18 months from
more than 395 daysSNotification 36 months after date of final rule 36 months effective date of final rule to
System Backup effective date of final 3ublication in Federal submit the updated ANS
Means rule pubictio design report to FEMA for
Register adequacy review, then 365
days to install/implement theANS backup means following
FEMA approval, with totaltime period to implementFEMA-approved ANS backupmeans not to exceed 3 years
and 6months from effective____date of final rule
12
EP Rule Implementation Dates
EmergencyOperationsFacility -
Performance-Based Approach
6 months after date offinal rule publication inFederal Register
No input180 days after date offinal rule publicationin Federal Register
No input180 days from effective dateof final ,rule
Emergency 1) 180 days from effectivedate of final rule to have
Response 6 months after date of 180 days after date of staging area andOrganization final rule publication in 36 months final rule publication 36 months communications capabilityAugmentation at
Alternative Federal Register in Federal Register 2) 36 months from effectiveFacility date of final rule to have
Facility_ remaining capabilities
1st biennial exercise 1) Licensees to conduct
1st biennial exercise more thanhostile action exercise for1 exrcis tha 395dayseach of their sites by
more than 1 year after after date of final rule 3+ ya 12i31i15.Challenging Drills effective date of final 6 months publication in Federal 3+ years 12/31/15.and Exercises rule2) States to fully participate
in one hostile action exerciseaction exercise by 12/31/15.
Protection for 6 months after date of 180 days after date of 180 days from effective dateOnsite Personnel final rule publication in 90 days final rule publication .90 days of final rule
Federal Register in Federal Register
NOTE: Applicants whose COL or ESP applications are docketed as of the final rule effective date will beallowed to defer compliance until December 31, 2013.
13
Offsite Emergency Preparedness Activities
May 3, 2011 James R. KishDirector
,PR Technological Hazards Division
FEMA
Topics" Presidential Policy Directive 8 (PPD 8)
" DHS-FEMA Administrator's Charge
" Other Related Preparedness Initiatives
" On-going Preparedness Activities
" Proposed FEMA Guidance: Revision of FEMA RadiologicalEmergency Preparedness (REP) Program Manual
" Moving forward on REP Program Manual and Supplement 4(Supp 4) to NUREG-0654/FEMA-REP-1 Rev. 1
" Next Steps - Beyond RPM and Supp 4
EAR.
~Q1FEMA
2
Presidential Policy Directive-8Directs the development of the following:* A National Preparedness Goal that'is risk informed, regionally
oriented, measurable, define core capabilities and emphasize anintegrated, layered, all-of-nation preparedness approach
" A National Preparedness System that is an integrated set ofguidance, programs and processes that guide planning,organization, equipment, training and exercises to build andmaintain domestic capabilities
" A comprehensive campaign to build and sustain nationalpreparedness including public outreach and community-based,and private-sector programs
" A National Preparedness Report an annual report that definesstrengths and weaknesses which will be used to inform thepreparation of the Administrations budget
FEAARTA.
0FEMA1ND S'C
3
FEMA Administrator's Chargem Assure that REP Program is fully integrated within FEMA.
n Maintain REP's compliance responsibilities, build on thecurrently strong system, while identifying FEMA capabilitiesthat should participate in preparedness activities.
m Align REP Program planning activities to be consistent withthe 'whole of community' planning effort.
* Enhance FEMA's Planning, Training and Exerciseparticipation related to radiological emergencypreparedness.
o FEMA4
Other Related Preparedness Initiatives" National Incident Management System (NIMS)
" National Response Framework (NRF)
" National Recovery Framework
" Comprehensive Preparedness Guide (CPG 101)
" Post-Katrina Emergency Management Reform Act
" Integration of Federal Radiological Preparedness PolicyCommittee (FRPCC) with IND and RDD hazards
" Outreach through National Advisory Council and NationalEmergency Management Association
qFEMA5
Proposed FEMA Guidance" REP Program Manual
" Supplement 4 to NUREG-0654/FEMA-REP-1, Rev.1 "Criteriafor Preparation and Evaluation of Radiological EmergencyResponse Plans and Preparedness in Support of NuclearPower Plants"
QXFEMA6
New REP Program Manual" Consolidated Implementation Guidance: Provide
comprehensive FEMA policy and interpretation of regulationsand guidance based on 44 CFR 350 and NUREG-0654/FEMA-REP-1, Rev. 1
" Alignment with National Preparedness Initiatives:. NationalIncident Management System (NIMS); National ResponseFramework (NRF); Homeland Security Exercise EvaluationProgram (HSEEP); National Preparedness Guidelines;National Preparedness Goal; Comprehensive PreparednessGuide (CPG 101); Post-Katrina Emergency ManagementReform Act
FEARVAR
r~FEMA7
New REP Program Manual (cont.)" Enhance REP Exercise Activities: Ensure more challenging
drills and exercises to enhance exercise activities
" Alignment with NRC's Regulations: Align FEMA guidancewith NRC regulations in 10 CFR Part 50 and NRC's proposedrulemaking activities
)FE.MA8
Proposed Supplement 4 Impacts" Hostile Action Based Events: Preparing for and
responding to hostile action-based (HAB) events at nuclearpower plants
" National Preparedness Initiatives: Aligning with NIMS;NRF; HSEEP; National Preparedness Guidelines; NationalPreparedness Goal; CPG 101; Post-Katrina EmergencyManagement Reform Act
m Enhanced Exercise Activities: Enhancing scenariorealism, ensuring challenging exercises, and reducingnegative training
" Alert & Notification: Ensuring backup means for Alert &Notification Systems
0 FEMA9
REP Program Manual & Supplement 4:Moving Forward
* Publication & Issuance:
" Public comment adjudication (FEMA and Joint FEMA-NRC)
" Pre-decisional status, release pending
* Implementation Strategy:
n Regional meetings to allow for questions and discussion
m Site specific workshops to assist local/state jurisdictionsincorporate updates and coordinate necessary updates toexisting schedules.
;FEMA10
Next Steps (Beyond RPM/Supp 4)Review of NUREG 0654/FEMA REP 1, Rev 1:
" Comprehensive look to include contemporary law,policy, and regulations
" Include findings from NRC Task Force, PPD 8implementation, and related preparedness initiatives
" Transparent process - stakeholder inclusive
iFEMA11
Minnesota Department ofPublic Safety
Division of Homeland Securityand Emergency Management
a
I
Kevin C Leuer, DirectorPreparedness Branch
May 3, 2011-/ ••-
~HSA
I Comment Overview HSEMr
*Implementation of NUREG0654 Supplement 3.
- Hostile Action Based (HAB)planning and response.
*New regulation impacts.
* Implementation of newrequirements.
NUREG 0654 Supplement 34 I*SEMR•~a Se~•.cr7d EiiwgIlcyMnamgnwimt
* Site specific implementation of stagedevacuation requirements.
* One size does not fit all. o blooo .0
= Predetermined PARs.
* Coordination between on
and off-site for PARs.
HAB Planning andResponse
* Synchronization of securityresponse and off-site radiologicalresponse plans is needed for aneffective hostile action basedresponse.
- Plant security response plansmust be integrated with the restof the response.
HSE rt
HAB PlanningAssumptions
* Prepare for designbasis events orbeyond design basisevents?
* With a radioactiverelease or without?
HSEMIWNoSmwtyndfomitwifm rmyMam-gw-wfl
I
Regulation Impacts QH$S* Hostile Action Response
" Many new players becoming involved.* Need federal agency participation in planning
and response.
p'Mft
* REP Program Manum New exercise cycle
Changesbut unknown exercise
criterion frequency demonstration requirements." Unknown HAB demonstration requirements." HSEEP implementation requirements. 6
Regulation Impacts HSE~t
*Response ImpactResponse to a crisis at the sitewhile responding to theradiological emergency.
* Jurisdiction Impacts" New law enforcement agency
impacts. .* New fire and EMS agency impacts." Tribal jurisdiction impacts.
/
Rule Implementation HSE&r
" Site specific implementation plan.
" Priority on hostile action
response implementation. ACAT RISK OF
- Consideration for states withmultiple sites.
" Consideration of budget cycles.°
" CY 2015 completion date.
8
Thank Youfor the opportunity to present today
0
I
Kevin C Leuer, DirectorPreparedness Branch
State Perspective onEP Rule
Patrick Mulligan, ManagerState of New Jersey
Department of Environmental ProtectionBureau of Nuclear Engineering
NRC Briefing on Emergency PreparednessMay 3, 2011
Positive Feedback on Process
m NRC was responsive to requests for an extendedcomment period
m Numerous Opportunities for stakeholderinvolvement
m Regional outreach and public meetings
m Comprehensive document summarizing publiccomments
m Stakeholder comments impacted Final Rule
State Concerns
* Dual Impact of both NRC and FEMArulemaking and guidance on state resources
* Events in Japan will require a comprehensiveanalysis of plant safety and design, emergencyresponse plans and the application of lessonslearned stretching limited resources
" Draft/Final FEMA guidance has not beenreleased for review
Federal Guidance Consistency
* Acceptance criteria for ANS systems is notcurrently available in any FEMA guidance
* NRC considering changes to NUREG-0654Supplement 3
" FEMA proposed changes to NUREG-0654Supplement 4
* NUREG-0654 initially issued as a jointdocument; need consistency
Backup Alert and Notification
System
" ISG-O1 recommends that no PI credit should begive for the backup ANS system
* No metrics to measure its contribution to theANS reliability PI.
" No Time requirement
m Question: If it has no effect on health and safetyand no design criteria, why is it regulated? Is achange to the current system necessary?
Exercise Schedule
" All offsite exercise objectives required by FEMAcannot be met during some of the suggested exercisescenarios.
* Off line and out-of-sequence exercises demand moretime, resources and funding.
" Added burden on state, county and local responseorganizations.
* FEMA must be consistent and flexible in allowingstates to meet these objectives with minimal impacts tostaffs and funding.
Future Rulemaking
" Supplement 3
" NUREG-0654
* Minimize impact/changes to recently adoptedrules and guidance
* Recognize the resources and time required toimplement current rule changes
* Continue to engage stakeholders early in thereview process.
EMERGENCYPREPAREDNESSWHAT'S WRONG?
May 3, 2011
Mary Lampert
Pilgrim Watch, Director
FUKUSHIMA'S LESSONS
Wake up Call or Snooze Alarm?
WHAT'S FUNDAMENTALLYWRONG?
#1
Rules Lack Specificity
Requirements
RULES PROVIDE FLEXIBILITYLACK ACCOUNTABILITY
Capability Based Rules -
* Licensee given flexibility* Licensee saves money* Licensee no real accountability
Performance Based Rules =
• EnforceablelAccountability
* Public Safety First
'4
WHAT'S FUNDA MEN TA L LYWRONG?
#2What Rules Do Not Address
Until the basic issues are faced-
no "reasonable assurance"
EMERGENCY PLANNING ZONE20125 MILES
NRC advised U.S. citizens inJapan within 50 miles to evacuate
* NRC says advice was an ..."ABUNDANCE OF CAUTION"
• Why not the same "ABUNDANCEOF CAUTION" for citizens here?
DOSE PROJECTIONSWhat's Wrong?
Likely Amount & Impact Radiation
Released Minimized
* PAGs not based on BEIR VII
" Large accidents ignored, e.g.
•spent fuel pool fire
) hydrogen explosions
~core or containment breach
more than 1% fuel failure
PLUME MODELINGWhat's Wrong?
Key Hole
Is
PLUME MODELING
What's Wrong?* Plume modeling based simplistic
straight-line, Gaussian plume; notsuited for complex sites (non-temporal, non-spatial)
What's Needed?• Advanced variable models and
multiple meteorological towersfor both pre-planning & response
9
NOTIFICATIONWhat's Wr?
Require Multiple RedundantSystems & Backup
• Sirens- outdoor alert
• Reverse 911- indoor alert
• Electronic Reader Boards
l Emergency Alert System
10
PROTECTIVE ACTIONSEVACUATION
What's Wrong?* Reception Centers equipped for
only 20% population.
Where will 80% get monitored,decontaminated, serviced?
* "Shadow Evacuation" ignored
* ETEs based "best case" scenario
I I
RADIOLOGICAL PROTECTION
POTASSIUM IODIDE (KI):- support stockpiling to 20 miles
(bioterrorism act, 2002)- require both tablets & liquid KI for
young children
3-M TYPE MASKS:-require stockpiling both adult &
children's sizes in schoolsishelters
12
EMERGENCY WORKERS
What's Wrong?* Communications: Require
in teroperability* Protective Gear: Require
protective clothinglmasks &training for its use
* REWMDs: RadiologicalEmergency Worker MonitoringDecontamination Centers- =requiremultiple centers per EPZ, located> 20 miles from reactor
RETURN & RECOVERY
What's Wrong?
" No Agreed Clean-Up Standard* No Federal Agency In Charge* No Money- Price Anderson pays
damages, not clean-upi MACCS2 (MELCOR Accident
Consequence Code System) isused but outdated - code severelyunderestimates offsite costs
14
4k
Emergency Planningfor the Possible
May 3, 2011Deborah Brancato
Staff Attorney, Riverkeeper, Inc.
RIVERKEEPER.NY's clean water advocate
Fundamental ProblemsOverlooked
The proposed final rule fails torequire consideration of andpreparation for all possible
emergency situations or instituteperformance based standards withwhich to ensure the effectivenessof nuclear power plant emergency
plans under all such situations
2
Licensees Must Prepare for"The Worst"
" 50-mile evacuation zone
* Accurate plume transport model
* Realistic ETE development
" Beyond design basis threats
* Adequate back-up Alert andNotification System
• Rapid escalation to GeneralEmergency
i Credible range of drill scenarios3
NRC Should ImplementPerformance-Based Standards
" ETEs
" Licensee coordination with OffsiteResponse Organizations
" Emergency declaration timeliness
" Drills
4
Other Recommendations
* Fully consider the lessons ofFukushima prior to finalizingNRC Staff's proposed final rule
" Incorporate emergencypreparedness into plant licenserenewal reviews
5
Indian Point
" Uniquely situated
* Existing Emergency Plan:
Completely Unworkable
Notable lack of confidence ineffectiveness of plan
" And yet, consistent NRC andFEMA approval
6
:6.
Industry Perspective onEP Rule
Tom JoycePresident and Chief Nuclear Officer
PSEG Nuclear
NRC Briefing on Emergency Preparedness
May 3, 2011
Positive Aspects of the Process
* Draft rule guidance provided for comment
well in advance of implementation
" Public meetings conducted to gather
stakeholder input
" Incorporation of review comments and
input improved the guidance
" New rule will improve several elements of
EP programs
Areas of Concern
* Changes that are not adequately justified ordo not have benefits commensurate withresources required to implement
- Drills and exercises, backup alert andnotification system, evacuation time
estimates, and emergency plan changeprocess
* Some elements of each lack a sound technical
basis or are inconsistent with Principles of
Good Regulation
Areas of Concern
* Guidance continues to evolve
On-shift collateral duty analysis
Task analyses should be required only for
positions not already analyzed by otherprograms or processes
-No additional formal comment period
C
Going Forward
" Finalize and issue staff guidancedocuments
" Timely staff review or endorsement ofindustry guidance documents
" Planned NRC/FEMA Workshops
" Implementation will be challenging forlicensees and State/local agencies
