National Radiological Emergency Preparedness Conference

National Radiological Emergency Preparedness Conference

By Patrick Mulligan (NJ), Chairperson, E-6 Committee on Emergency Response Planning

Mr. Patrick Mulligan attended the 16^th Annual National Radiological Emergency Preparedness (NREP) Conference in St. Louis, Missouri, from March 27 through March 31, 2006. Mr. Mulligan was invited by the Conference Steering Committee to make a presentation on the CRCPD and the E-6 Committee activities for the past year. This year, the presentation time allotted was split between the E-6 Committee and the HS-5 Committee, chaired by Adela Salame-Alfie, Ph.D. Mr. Mulligan provided an overview of the CRCPD organization including its mission, goals, members, and functions.

For many years, the E-6 Committee was afforded the opportunity to hold an annual meeting of members and advisors at the NREP Conference. These meetings provided a forum for the committee to discuss ongoing activities, upcoming projects, Federal guidance issues, and revisions to the charges and mandates of the committee. During these meetings, liaisons from the various Federal agencies that the E-6 Committee interacts with were asked to attend. This provided an opportunity to have open discussions with our Federal partners regarding initiatives that would involve the participation of the committee members and advisors.

Due to budget constraints at the State, Federal and organizational level, the meetings have not been well attended for the past few years. Three committee members, one advisor, and one emeritus member attended this year's E-6 meeting during the week of the NREP conference. Federal participants at the off-hours meeting included the Environmental Protection Agency (EPA), the Department of Homeland Security (DHS), and the Department of Energy (DOE).

The focus of the conversation was communication. With the ever-changing structure within each of the Federal organizations with regard to the National Incident Management System / Incident Command System framework, it is increasingly difficult to maintain a single point of contact.

E-6 is working hard to maintain the close working relationship with our Radiological Emergency Preparedness (REP) counterparts within the Federal agencies and reiterated the value that the committee can bring to Federal working groups and committees.

The Nuclear Regulatory Commission (NRC) provided the conference attendees with an update on REP-related activities within the organization. The overarching theme for their presentation was the integration of security with emergency preparedness. Over the past year, the NRC has been involved with a comprehensive review of its radiological preparedness and planning program. The review resulted in a number of initiatives that were released for use industry-wide in Regulatory Issue Summaries (RIS) and Bulletins. The most notable was "NRC Bulletin 2005-02: Emergency Preparedness and Response Actions for Security-Based Events" (July 18, 2005).

The bulletin addressed four specific issues. First was to notify licensees about NRC’s need for information associated with emergency preparedness (EP) for security-based events at a nuclear power plant. Second was to request licensees provide information to the NRC within 30 days of the bulletin regarding actions taken or planned to be taken in certain areas. These areas included security-based emergency classification levels and emergency action levels (EALs), emergency response organization augmentation for security-based events, and a security-based EP drill and exercise program. The NRC also requested that the industry make accelerated NRC notifications and onsite protective measures on discovery of a security-related event. Third, if actions regarding the topics covered in the bulletin were not being taken, the addressees were requested to provide a schedule detailing expected completion dates for all pending activities. Finally, the bulletin required addressees to provide a written response to the NRC in accordance with 10 CFR 50.54(f).

On Wednesday, August 31, 2005, and Thursday, September 1, 2005, the NRC hosted a Roundtable Public Meeting in Rockville, Maryland. The purpose of the meeting was to discuss selected topics for the review of emergency preparedness regulations and guidance for commercial nuclear power plants and to obtain stakeholder input. One of the topics was the information and guidance contained in Bulletin 2005-02. The selected topics also included EP related issues that arose during the NRC/Federal Emergency Management Agency (FEMA) workshop at the 2005 NREP Conference. In addition to the comments provided by attendees during the meeting, the NRC accepted written comments. Mr. Patrick Mulligan represented the CRCPD as the E-6 Committee Chair. All documents related to the meeting, including transcripts from the meeting and comments and DHS/NRC responses, can be found at http://www.nrc.gov/public-involve/public-meetings/epreview2005.html.

The NRC is sponsoring a study of Protective Action Recommendations (PAR). This study is designed to assist the nuclear industry in addressing the NRC request that all licensees reconsider sheltering as a PAR for nuclear emergencies. Mr. Randolph Sullivan, NRC, provided an update on the status of the study during one of the conference sessions. The initial steps of the study included a review of the pertinent planning basis documents and guidance on protective measures found in Supplement 3 to NUREG-0654/FEMA-REP-1. The scope of the study included a broad spectrum of nuclear power plant accidents, improvements in evacuation time estimates, additional sheltering strategies, additional evacuation strategies, and fast-breaking accident scenarios.

Alternative PAR regimens that were assessed in the study included shelter in place, preferred sheltering for various times in large buildings, lateral evacuation, and staged evacuation. The goal of the study was to determine if any of the alternative protective measures to evacuation provided an overall dose reduction to the affected population. Various dose consequence scenarios were used to assess the dose reduction. The initial conclusions from the study are that sheltering in place can result in dose reduction to the public for rapidly developing short-term releases. Sheltering for these events should be followed by evacuation after the plume passes to avoid further doses from deposited materials. The study will continue with an analysis of likely public reaction to protective action decisions other than evacuation. Based on the initial finding, no changes to Supplement 3 are imminent.

The NRC and DHS are working together to develop security-based drills and exercises that will become part of the six-year evaluation cycle for nuclear power plants. The security-based exercises will differ from routine radiological exercises in that the focus will not be on a response to a radiological release. Both the NRC and DHS agree that those aspects of a radiological response will be adequately covered in the other two exercises of the six-year cycle.

The initiative to develop security-based exercises has four phases. Phase I includes tabletop drills that will assist in the development and refinement of onsite and offsite guidance and objectives for a terrorist-related scenario. Phase II will include conducting integrated drills to validate the guidance and objectives under more traditional evaluated exercise conditions. Phase III will be to finalize the guidance documents, conduct an industry lessons learned workshop, and obtain official NRC and DHS endorsement. Phase IV will be to incorporate the security-based drills into the REP exercise evaluation program. There will be multiple opportunities for State, local, and tribal response organizations to provide input, feedback, and comments on the development of this initiative.

At some point within the development process, the DHS will need to review and revise the evaluation criteria for security-related exercises. The Nuclear Energy Institute has released a White Paper on the development of security-related drills and exercises and submitted the document for NRC endorsement. That document is available for review and comment.

The DHS provided a detailed update on activities and initiatives to the Conference in a plenary session. During the update, the DHS publicly recognized that NUREG-0654 (the planning basis for all Radiological Emergency Response Plans) is severely outdated and needs a total overhaul to make the document current. The DHS plans to undertake this project in the near future. The E-6 Committee needs to be involved with this process through the Federal Radiological Preparedness Coordinating Committee.

The DHS confirmed that security-based exercises will be part of the six-year evaluation schedule for DHS. These exercises will not be in addition to the normal schedule, but will replace one of the radiological exercises during the cycle. Evaluation criteria for the exercises need to be addressed. There are four phases to this project (discussed in the NRC update above).

The DHS provided a presentation on the guidance document titled, "Protective Action Guides for Radiological Dispersal Device (RDD) and Improvised Nuclear Device (IND)” that was released for comment in Federal Register/Vol. 71, No.1, Tuesday, January 3, 2006. The closing date for comments was April 14, 2006. Although the document focuses on INDs and RDDs, the final section for long-term return and recovery (optimization framework) may very well be applied to REP-related occurrences in the future. It may be the groundwork for Chapter 6 of the revised EPA-400 Manual of Protective Actions.

Other sections of the document endorse the current development practices for the development of PARs found in the EPA-400 Manual of Protective Actions with a few exceptions. An important part of this document will be the development of operational guidelines for radioactive materials by the DOE. The operational guidelines will be used in the optimization process for return and recovery. Updates to the operational guidelines will be posted on the DOE's website as they are developed. The DOE will solicit public comments on the guidelines.

The DOE provided the conference with an update on the Consequence Management Home Team Concept. Sandia National Laboratory (SNL) has the lead for the development of a new concept for Consequence Management Home Team assets designed to provide support to the State before the Consequence Management Response Team I (CMRT) arrives onsite. The main component of the CM Home Team will be located at the Remote Sensing Laboratory (RSL) in Las Vegas, Nevada. They will coordinate information with the Home Team at SNL and the National Atmospheric Release Advisory Center (NARAC). A permanent bridge line will be established at RSL to facilitate coordination. RSL and SNL will still mesh with NARAC to provide predictive models, but as real data come in they will transition to maps to be provided by the Federal Radiological Monitoring and Assessment Center (FRMAC).

The DOE continues to hold regular meetings of working groups addressing the review and revision to FRMAC Manuals. E-6 participates on each of these working groups and works closely with the DOE on all issues related to FRMAC. DOE is working on a revision to the model Turbo-FRMAC that will have enhanced capabilities and be more user-friendly. The DOE Laboratory Analysis Work Group is continuing the review and revising of the Radiological Organization Database for Emergency Operations (RODEO) for data management at FRMAC. Finally, FRMAC will finalize the operational changes needed to come into compliance with the NIMS/ICS framework for response to radiological emergencies.

The EPA is currently working with other federal agencies to review and revise the operational procedures for the Advisory Team. The group also is working on training initiatives for regional response staff and outreach for State and local response organizations. The Advisory Team activities have been subdivided into four working groups. The E-6 Committee has members and advisors assigned to each of these working groups. Finally, EPA is hoping to finalize revisions to EPA-400 in the near future. The revised document has been put on hold pending the DHS development of a framework for addressing return and recovery issues.

All presentations and abstracts from conference presentations and break out sessions will be made available on the NREP web site in the near future. The webpage for the NREP conference is http://www.nationalrep.org.

June 2006