NRC UPDATE EP REGULATORY ACTIVITIES Glenn M. Tracy / Kathy Halvey Gibson Office of Nuclear Reactor Regulation National Radiological Emergency Preparedness Conference Nashville, Tennessee April 2, 2001
Summary The Nuclear Regulatory Commission (NRC) presented an update of the emergency preparedness (EP) activities in which the agency is currently engaged. One of the primary activities is the reactor oversight program (ROP), a new methodology for oversight of nuclear power plant operations including EP. Under ROP, EP is recognized as one of the cornerstones of safety and the final barrier between reactor operations and protection of the public. To monitor the EP cornerstone, the NRC uses two processes that generate information about the safety significance of plant operations, a risk-informed inspection program and licensee reported data used to calculate performance indicators (PIs). Another major EP activity involves implementation of the final rule requiring the consideration of potassium iodide (KI) in emergency planning. Other current NRC EP activities include development of emergency planning requirements for nuclear power plants undergoing decommissioning; resolution of issues related to the development of new emergency action level (EAL) guidance by the industry in NEI 99-01 (Rev. 4, September 2000); a rulemaking initiative to clarify the regulatory requirements regarding NRC approval of EALs; a rulemaking initiative to clarify the exercise requirements for sites with co-located licensees; a rulemaking initiative to revise the frequency of offsite exercises to support the FEMA recommendation that offsite authorities be given the option demonstrating reasonable assurance by alternative means other than an exercise during one biennial period in a six-year cycle; preparation of a NUREG to provide the results of a study to assist emergency response organizations in estimating the total dose (internal and external) received by emergency workers; and the review of a General Electric Owners Group topical report seeking the elimination of postaccident sampling systems (PASS). The NRC also noted that the alternative radiological source terms approved for use for evaluating design basis accidents cannot be used as the basis for requesting relief from EP requirements. Glenn Tracy is the Chief of Reactor Operator Licensing, Human Performance and Plant Support Branch, within the Office of Nuclear Reactor Regulation of NRC. Glenn is responsible for several reactor program areas including emergency preparedness, radiation protection, reactor security and safeguards, and the licensing of nuclear power plant operators. Glenn has held several key NRC assignments, including service as the Chief of Staff for the NRC Chairman, Dr. Richard A. Meserve. Prior to that assignment, Glenn was the Chief of Staff for the NRC Executive Director for Operations, Dr. William D. Travers, the senior career federal executive reporting directly to the Commission. Glenn has also served as Deputy Director of the Division of Reactor Safety in Region IV and Chief of the Performance Evaluation and Assessment Section in the Inspection Program Branch. Prior his arrival in NRC headquarters, Glenn was a regional inspector, serving as the senior resident inspector at the Indian Point 3 nuclear power plant in New York. Glenn effectively dealt with a multitude of issues and stakeholder concerns, earning NRC s Meritorious Service Award for Inspection Excellence. Before joining NRC, Glenn was a senior project engineer in the fluids engineering department for a major building products manufacturer after serving seven years in the U.S. submarine service. Glenn earned his engineering degree from the U.S. Naval Academy in 1982. Kathy Halvey Gibson is the Chief, Emergency Preparedness and Health Physics Section, Office of Nuclear Reactor Regulation, US Nuclear Regulatory Commission being selected to this position effective July 2, 2000. Ms. Gibson had relocated to NRC headquarters from the NRC s Technical Training Center in Chattanooga, TN, where she held progressively responsible positions including Reactor Technology Instructor, Section Chief, Branch Chief and Assistant to the Director. Ms. Gibson joined the NRC in 1986 as a Reactor Inspector in Region I and was shortly thereafter selected as Resident Inspector at the Salem Nuclear Generating Station in New Jersey. In 1989, she was selected as the NRC s first female Senior Resident Inspector. Ms. Gibson came to the NRC from Duquesne Light Company, Pittsburgh, PA, where she held progressively responsible chemistry positions at Shippingport Atomic Power Station, and quality assurance positions at Beaver Valley Power Station. Ms. Gibson received her Bachelor of Science degree in Chemistry, Biology and Natural Sciences from Indiana University of Pennsylvania, Indiana, PA, and has done graduate work in Nuclear Science and Engineering at Carnegie-Mellon University, Pittsburgh, PA. Ms. Gibson is married and has four children.
REACTOR OVERSIGHT PROGRAM (ROP) The NRC implemented the new methodology for oversight of nuclear power plant operations, including Emergency Preparedness in April 2000 A Lessons Learned Workshop was conducted in March 2001. While minor revisions are going forward, no major focus group issues were identified for EP. Initial implementation of the EP ROP is providing adequate oversight Emergency Preparedness is recognized as the final barrier between reactor operations and protection of the public - EP is one of the cornerstones of safety To monitor the EP cornerstone, NRC uses two processes that generate information about the safety significance of plant operations, a Risk-Informed Inspection Program, and Licensee reported data used to calculate Performance Indicators (PIs) The EP Performance Indicators are: Drill/Exercise Performance (DEP) Emergency Response Organization Drill Participation (ERO) Alert and Notification System Reliability (ANS) Inspection findings are evaluated according to their potential significance for safety, using the Significance Determination Process ROP - INSPECTION FINDINGS GREEN findings are indicative of issues that, while they may not be desirable, represent very low safety significance. There have been 18 green findings as of the 4 th Quarter 2000 Inadequate corrective actions Inadequate revision/correction of EALs Elements of critiques inadequate Missed surveillance tests and drills Untimely declaration of unusual event
ROP - INSPECTION FINDINGS (cont) WHITE findings indicate issues that are of low to moderate safety significance. There have been five white findings: Two in the lack of ability for timely augmentation of the ERO One for a poor critique of exercise One for poor media center activation and operation One for poor program for worker protection YELLOW findings are issues that are of substantial safety significance. There have been no yellow findings in EP RED findings represent issues that are of high safety significance with a significant reduction in safety margin. There have been no red findings in EP ROP - PERFORMANCE INDICATOR ISSUES GREEN indicators represent performance at a level requiring no additional NRC oversight beyond the baseline inspections. WHITE corresponds to performance that may result in increased NRC oversight. A few sites have had intermittent siren problems or system failures that have resulted in the PI crossing the white threshold. Generally, these problems have been solved and the PI returned to green quickly. YELLOW represents performance that minimally reduces safety margin and requires even more NRC oversight. One site has had siren reliability problems degrade to the point of a Yellow PI. Considerable effort has been put forth to improve siren reliability and the sirens are currently in the white region RED indicates performance that represents a significant reduction in safety margin but still provides adequate protection to public health and safety. There are no Red thresholds for EP PIs.
POTASSIUM IODIDE (KI) NRC issued a final rule on the consideration of KI in emergency plans in a Federal Register Notice on January 19, 2001 (66 FR 13 page 5427 to 5440) The final rule amends 10 CFR 50.47(b)(10) to require that consideration be given to including the use of KI as a protective measure for the general public in the plume exposure pathway EPZ that would serve as a supplement to sheltering and evacuation. Under this rule the use of KI continues to be a State and, in some cases, local option. The Commission has agreed to provide funding for a supply of KI for State governments that choose to incorporate KI for the general public in their emergency plans. NRC is working closely with FEMA on rule and resource implementation issues NRC/FEMA activities will be discussed in detail during the KI panel EP REQUIREMENTS FOR DECOMMISSIONING Currently decommissioning nuclear power plants request exemptions from 10 CFR 50 regulations, including EP Rulemaking would eliminate the need for case-by-case exemptions (latest rulemaking plan 6/2000) Commission decided to further analyze SFP accident risk and impact of potential spent fuel pool zirconium fire Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants (Technical Study or TWG) issued January 17, 2001 (2 draft reports issued for public comment; 14 public meetings; 5 agency meetings - Commission and ACRS) Risk at decommissioning plants is low and within the Commission s Safety Goals During decommissioning the primary safety concern involves the fuel stored in the spent fuel pool (SFP) In the absence of cooling, either by water or air flow, the fuel rods could heat up to where the oxidation of the zirconium fuel cladding becomes self-sustaining, the so-called zirconium fire
EP REQUIREMENTS FOR DECOMMISSIONING (cont) A significant finding of the Technical Study is that it is not feasible to define a generic decay heat level (and therefore decay heat time) beyond which a zirconium fire is not physically possible Exemptions have been granted based on: Doses from any reasonably conceivable SFP accident do not exceed EPA PAGs Sufficient time for mitigative actions and if necessary offsite protective measures for bounding case (zirconium fire) without preplanning Current decommissioning plants: 3 years decay time = ~20 hours to zirconium fire based on the Technical Study Exemptions included: No offsite EP required Reduced onsite EP Emergency Action Levels to an Alert NRC Staff has begun development of a Policy Paper for Commission approval regarding the appropriateness of reducing or eliminating offsite EP requirements NRC Staff and FEMA established a working group to discuss the technical issues (first meeting March 9, 2001) EMERGENCY ACTION LEVEL (EAL) GUIDANCE EALs are based primarily on in-plant conditions and instrumentation and are used as thresholds for declaring and classifying emergencies Guidance for EAL development is given in: NUREG-0654/FEMA-REP-1 NUMARC/NESP-007, endorsed by NRC in RG 1.101, Rev 3, 8/92 NEI submitted NEI 99-01, Methodology for Development of Emergency Action Levels, Final Draft Revision 4, on 2/28/00, and requested NRC s endorsement
EAL GUIDANCE(Cont) NEI 99 01 provides new EAL guidance for: Shutdown and refueling modes of plant operation Permanently shutdown reactors and dry cask spent fuel storage Revised EAL guidance based on experience gained in using NUMARC/NESP-007 NRC issued Draft Reg Guide DG-1075, a proposed Rev 4 to Reg Guide 1.101 which would endorse the use of NEI 99-01, in a Federal Register Notice in March 2000 NRC and NEI worked together in a cooperative manner to resolve the public comments NEI issued NEI 99-01, Rev 4, Final Methodology for Development of Emergency Action Levels, on September 8, 2000 The endorsement of NEI 99-01, Rev 4 is on hold pending the resolution of issues raised by the Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants. RULEMAKING INITIATIVE TO CLARIFY REQUIREMENTS REGARDING NRC APPROVAL OF EALs NRC is considering options for clarifying requirements regarding NRC approval of changes to emergency action levels (EALs) 10 CFR 50, Appendix E, Section IV.B, requires NRC approval of EALs 10 CFR 50.54(q) allows licensees to make EAL changes without prior NRC approval if there is no decrease in effectiveness of the emergency plan NRC staff developing a rulemaking plan to address this conflict in the regulations regarding EAL changes Licensees can continue current practice of making EAL changes without prior NRC approval; NRC reviews all EAL changes RULEMAKING TO CLARIFY EXERCISE REQUIREMENTS FOR CO-LOCATED LICENSEES NRC Regulatory Requirements for Exercises Each licensee at each site shall conduct an exercise of its onsite emergency plan every 2 years
Offsite plans for each site shall be exercised biennially with full or partial participation by each offsite authority having a role in the plan The only sites currently with co-located licensees are Indian Point (IP2 and IP3) and Nine Mile Point / FitzPatrick Other than these sites, licensees have been participating in an integrated onsite and offsite EP exercise every 2 years with full or partial participation of the offsite authorities The practice at IP, and Nine Mile/ FitzPatrick, has been to alternate the participation between licensees in the required biennial offsite exercises The unique considerations raised by co-located licensees most likely were not considered by the Commission when it established its regulatory requirements for exercises Two possible interpretations of the regulations - 1) the current practice of each licensee participating in an exercise with offsite authorities every four years, or 2) each licensee should participate in an exercise with offsite authorities (either full or partial) every two years. The current rules could be interpreted to permit a range of practices. The NRC has reasonable assurance that EP at IP, and NMP/JAF, is adequate based on NRC findings on onsite, FEMA findings on offsite EP, and on the current level of interactions between licensees and offsite authorities in the period between full participation exercises. The licensees have documented and committed to continue current level of interactions between each licensee and offsite authorities in the period between full participation exercises. Rulemaking plan to amend the EP regulations to remove ambiguities about the required conduct of exercises and to clarify the terms licensee and site is due to the Commission in June 2001 RULEMAKING TO REVISE OFFSITE EXERCISE FREQUENCY A rulemaking plan is being developed to support FEMA OSWG Recommended Initiative 1.11, Negotiate 6-Year Agreements NRC regulations require that an exercise of the offsite emergency plans be conducted every two years
The proposed rule change would give offsite authorities the option of foregoing one of the biennial exercises in a 6-year cycle and allow the demonstration of reasonable assurance by alternative means Offsite authorities would negotiate with FEMA the alternative means to demonstrate reasonable assurance in the biennial period in which an exercise is not conducted RADIOLOGICAL EMERGENCY WORKER DOSE The need for data that could be used by EROs to estimate the total dose (internal and external) received by emergency workers was identified during the FEMA Strategic Review Emergency worker dose is monitored by personal dosimetry which measures external dose only The NRC is performing a study of the estimates of the ratio of the: TEDE - sum of the dose commitment from internal and external exposure to a radioactive plume DDE - the deep dose equivalent, the dose commitment from external exposure only The TEDE/DDE ratio is dependent on many factors - time after reactor shutdown, extent of core damage, effects of reduction factors such as containment spray, and meteorological conditions Calculations were performed with NRC RASCAL computer code Preliminary results indicate that the TEDE ratio ranges from 1 to 5 if emergency workers have taken KI to minimize internal exposure The NRC is preparing a draft NUREG document to provide the results of the study which will be issued for public comment POST-ACCIDENT SAMPLING SYSTEMS (PASS) PASS required after TMI-2 accident to obtain in-plant radiological and chemical information to support emergency response, accident management, and recovery actions PASS objective was to provide information within 3 hours of decision to obtain sample
Utility Owner Groups (CE, W) submitted topical reports seeking elimination of PASS - rationale was that data from PASS is unreliable, not timely, and can be obtained by other means NRC requested public comment on the elimination of PASS in a Federal Register Notice on November 24, 1999 NRC acceptance reports issued for Combustion Engineering Owners Group on May 16, 2000 (ML003715250), and Westinghouse Owners Group on June 14, 2000 (ML003723268) These reports can be referenced by individual licensees seeking to eliminate PASS at their plants GE BWR Owners Group submitted a request for relaxation of PASS commitments. NRC acceptance report has not yet been issued. While the NRC agrees that PASS can be eliminated, licensees will be required to: Establish a capability for classifying fuel damage events at the Alert level threshold Develop contingency plans for obtaining and analyzing reactor coolant and containment sump and atmosphere samples Maintain offsite capability to monitor radioactive iodines Make a determination that there will be no decrease in the effectiveness of the Emergency Plans ALTERNATIVE SOURCE TERMS (AST) The NRC has amended its regulations to allow licensees to voluntarily replace the source terms used in Design Basis Accidents with alternative source terms (64 FR 71990, 12/23/99) The revised source terms postulate that the core inventory is released in a sequence of phases over 10 hours with the more significant release beginning at about 30 minutes from the start of the event Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating DBA s at Nuclear Power Plants, was issued in July 2000(ML003716792)
Regarding EP, Reg Guide 1.183 states: Although the AST was based on a limited spectrum of severe accidents, the AST has been tailored specifically for DBA use The AST is not representative of the wide spectrum of possible events that make up the planning basis for EP The AST is insufficient, by itself, as a basis for requesting relief from the EP regulatory requirements The insights of the AST may be used in developing emergency response procedures such as emergency dose projections, protective measures, and severe accident management guidelines