EMERGENCY PREPAREDNESS A VISION FOR THE FUTURE NREP April 22, 2009

1. EMERGENCY PREPAREDNESS A VISION FOR THE FUTURENREP April 22, 2009 Alan Nelson Director Emergency Preparedness Nuclear Energy Institute

2. Discussion Topics • Industry’s Commitment • Nuclear Energy Institute • Regulatory Enhancements • Looking Ahead • Moving to the Future

3. Nuclear Industry’s Commitment to Emergency Preparedness • A commitment to excellence throughout the industry coupled with continual training, self-assessment, and testing has produced a high level of preparedness • Effective methods assess performance in drills and exercises • Lessons learned from actual events, drills, exercises, and independent critiques • State-of-the-art response facilities • Communication technology are used as effective tools for dealing with emergencies

4. Historical View • Edison Electrical Institute • Atomic Industrial Forum • Nuclear Management and Resources Council • National Radiological Preparedness Conference • Nuclear Energy Institute

5. Nuclear Energy Institute • The Washington, D.C. policy organization of the nuclear energy industry • NEI’s MISSION • To create favorable U.S. Energy policy for the continued safe use of nuclear energy

6. Nuclear Energy Institute PURPOSE • Provide unified policy direction on regulation and legislation • Represent nuclear industry before congress, executive agencies, federal regulatory bodies, and state policy forums • Disseminate positive information about nuclear energy to policy-makers and the public

7. Emergency PreparednessEssential Issue • Emergency preparedness involves technical or operational issues of significance that can have political and financial impacts on all, or most of the industry

8. NEI Oversight and Support • Nuclear Strategic Issues Committee • Emergency Preparedness Working Group • Task Forces • Draft Rulemaking • Protective Action Strategies • Emergency Action Levels • Hostile Action Based Drills • Frequently Asked Questions • New Plant Applications

9. Regulatory Enhancements • Schedule • Federal Register • 75 day comment period comments due • NEI will request a longer public comment period • Support each of the public meetings

10. NRC Specific Request for Comments • Inclusion of National Incident Management System/Incident Command System • Staffing and Augmentation – alternative approach 3-5. Expand to Non-power Reactors • Effective date for new plant licensees • Implementation schedule

11. Eleven Main Areas Addressed • Licensee on-shift ERO roles and responsibilities • EALs for hostile action threat events • Alternative ERO augmentation and alternate facilities • Licensee coordination with OROs • Protection for on-site personnel during hostile action event • Conduct of security drills and exercises • Alert Notification System backup capabilities • Event identification and classification time lines • EOFs – performance based approach • Evacuation travel estimate updating • Emergency Plan change process

12. 1. On-Shift Multiple Responsibilities • NRC has been pursuing revising Table B-1 since the mid 1990’s • Security efforts have put additional strains on minimum shift resources • Industry Perspective • Industry is committed to staffing our nuclear plants consistent with the goal of nuclear safety • Staffing requirements must be consistent with probable outcomes and not based on a completely unlikely scenario

13. 1. Impact On-Shift Multiple Responsibilities • Licensee would have to perform a job task analysis to determine functional responsibilities • There is some consideration for the use of a tabular approach that would modify the current table B-1 in NUREG 0654/FEMA- REP-1

14. 2. EALs for Hostile Action Threat Events • NRC will codify requirements for existing Emergency Action Levels that were created based on NRC Orders to Licensees in 2002 and 2005 • Licensees and OROs have already incorporated threat EALs into their program

15. 2. Impacts EALs for Hostile Action Threat Events • EALs in the proposed rule are already in effect • Licensees will include security / hostile action based events that address these EALs in drills and exercises • FEMA should consider these EALs and associated events in evaluating exercises and reasonable assurance

16. 3. ERO Augmentation and Alternate Facilities • Concern that during a hostile action event some facilities such as TSC, OSC, EOF may not be available to perform function • Solution is to require alternate facilities capable of • Staging on site responders • Performing off site notifications • Repair team preparation / dispatch • Additional operational requirements may include • Obtaining and display of key plant data • Capability to analyze plant technical information • Ability to provide briefings on event conditions and prognosis to licensee and off site responders

17. 3. Impact Alternative ERO Augmentation Facilities • Possible impact for extent of play and evaluation of such capabilities

18. 4. Licensee Coordination with OROs • NRC will require licensees to ensure that OROs will support and have capabilities required to respond to hostile action events Existing mutual aid agreements will satisfy this requirement according to NRC presentation at RIC. • OROs already have the expected capabilities and will demonstrate during hostile action threat drills that will be conducted as part of 6-year exercise cycle.

19. 4. Offsite Impact Coordination with OROs • Licensees will have to evaluate ORO capabilities related to hostile action threat response (LLEA, traffic control, fire response, EMS, field monitoring) • OROs may have to demonstrate existing capabilities augmented resources of existing capabilities procedures • FEMA expected to develop its own review criteria which should be in NUREG 0654/FEMA REP-1 supplement 4.

20. 5. Protection of On-Site Personnel during Hostile Action Event • 10 CFR 50 Appendix E Section I will require that Licensees will have to develop a range of protective actions for on site personnel

21. 5. Impacts on Licensees and OROs • Unknown impacts until we see the NRC’s interim staff guidance • OROs and licensees generally have existing relationships to ensure that on site personnel can be protected when on site security forces are at capability limits

22. 6. Conduct of Security Drills and Exercises • As part of the 6 or 8 year exercise cycle licensee and ORO will conduct REP / hostile action based drills/exercises • As part of drill and exercise program, scenarios will have to encompass a wide spectrum of events from those that demonstrate mitigation with little or no radiological impact to those that demonstrate severe damage and release (typical of current REP biennial plume exposure exercises).

23. 6. Impacts on Licensees and OROs • NEI will revise NEI 06-04 to reflect lessons learned from HAB program and request NRC endorsement • Licensees will have to develop a much larger library of exercises with a range from little to major consequence. • Major impact on extent of play to enable more realistic exercise scope

24. 7. Alert Notification Back Up Capabilities • Recommends amending regulations to require a compensatory means to notify the public if the primary system is unavailable • Replaces concept of requiring backup power to sirens • Goal is to evaluate technologies and other methods

25. 7. Impact Alert Notification Back Up Capabilities • Confirmation and effectiveness of route alerting • Anticipate that FEMA will revise REP-10 to provide for such changes and the changes should be consistent with the national alerting criteria being prepared by DHS

26. 8. Emergency ClassificationTimeliness • SEC’Y attempts to codify the Performance Indicator commitment to classify within 15 minutes • The 15 minute criteria forcing a decision could negatively impact safety if improper classifications are made • Industry Perspective • Current criteria for “timely” classification is appropriate. For the few actual events timely should be assessed based on circumstances.

27. 8. Impacts on Licensees and OROs • Actual events may be complex and take time to appropriately evaluate. The 15 minute criteria forcing a decision could actually wind up negatively impacting safety and possible offsite actions if improper classifications were made because clock ran out

28. 9.Performance Based Consolidated EOFs • Establishes need to set criteria for Common fleet EOFs and Standard Plans • Efforts now require exemption and considerable regulatory interface • Industry Perspective • Industry should endorse the concept for standard criteria.

29. 9. Impacts on Licensees and OROs • Impact will be determined on site by site basis

30. 10. Evacuation Time Estimate (ETE) Updates • New update required if there is a + 10% change in population of the EPZ in a year period • NRC will issue new ETE development guidance • Basis is NUREG/CR 6953 or a new guidance document that will be issued along with the proposed rules • Presumption is that accurate ETEs help licensees and OROs in developing more suitable protective action strategies, tactics and directions

31. 10. Impacts Evacuation Time Estimate Updates • Impact on licensees to regularly monitor population data and develop new ETEs • ETE experts believes 10% change is unrealistically low • Impact on OROs – If the evaluation is done to soon the results will have marginal value

32. 11. Emergency Plan Change Process • Develop a consistent repeatable definition for Reduction In Effectiveness (RIE) • Industry Perspective • Strongly endorse the concept of a repeatable consistent definition • NRC should consider NEI proposed definition • NEI will propose industry guidance for NRC endorsement

33. 11. Impacts Emergency Plan Change Process • Licensees may have to maintain configuration control approach to E-plan and EP facilities, structures, infrastructure • Licensees may maintain a configuration control system to determine whether or not a change in the plant affects the emergency plan

34. Concerns • We believe that there is significant impact on FEMA and our offsite counterparts • NRC rulemaking cross cuts DHS and FEMA authority – regulatory authority could cause inconsistency and subjectivity during evaluation: • Existing “all hazard” capabilities of OROs • Alert and Notification • ORO response capabilities • Evacuation Time Estimates

35. Concerns • It’s not appropriate to address these in the context of nuclear power plants • There are existing Presidential directives for all hazards approaches to emergency communications, incident management (NIMS), and the National Exercise Program

36. Looking Ahead • Reflecting on NEI mission • NEI has identified industry subject matter experts for each of the 11 draft rulemaking recommendations • Evaluation of each has been completed along with bench marking a number of critical areas • Licensees should brief their offsite counterparts and self identify areas of concern

37. Looking Ahead • NEI will develop industry response incorporating your concerns • Licensees should discuss the many impacts of the rule with their offsite counterparts and encourage them to respond and attend NRC/FEMA public meetings • NEI will attend each of the NRC/FEMA public meetings

38. Hostile Action-Based DrillsOpen Forum SessionApril 23, 2009 1:00 to 4:45 pm • Improving Coordinated Stakeholder Response Through Discussion of Preparation Techniques and Key Observations

39. Moving to the Future Marty Hug Sr Project Manager Emergency Preparedness Nuclear Energy Institute Phone: (202) 739-8129 Mobile: (202) 439-0768 Email: mth@nei.org Sue Perkins-Grew Sr. Project Manager Nuclear Energy Institute phone: 603.773.7278 mobile: 202.247.8163 email: spg@nei.org