U.S. NRC Blog

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Even the Best Guidance Can Be Updated

Don Tailleart
Regulatory Improvements Team Leader
Office of Nuclear Security and Incident Response

 

Well-written documents can stand the test of time – just look at the Declaration of Independence. The NRC and FEMA aimed for durability 30 years ago as we responded to the Three Mile Island accident. We co-wrote criteria for nuclear power plants to prepare and evaluate emergency response plans and preparedness programs. That guidance document has been the go-to standard for plant staff, and emergency preparedness managers at the state, local and tribal level.

The NRC and FEMA realized, however, that when a document starts showing its age it’s time for a revision. That’s why a joint NRC/FEMA team is revising NUREG-0654/FEMA-REP-1. This is an update rather than a complete rewrite. Our aim is to make the guidance more user-friendly by restructuring and streamlining it with a focus on evaluation criteria.

Evaluation criteria, by the way, are the parts of emergency plans and preparedness programs that directly respond to NRC or FEMA requirements. Both agencies use evaluation criteria when reviewing emergency plans to make sure the preparedness programs are acceptable.

Before starting on the revision, the NRC and FEMA took suggestions from the public and interested groups. Our writing teams used that information to refocus preliminary evaluation criteria language on capabilities and overall program elements. We’ve moved more detailed information on evaluation criteria implementation to a new NRC emergency preparedness guidance document and to the FEMA Radiological Emergency Preparedness Program Manual.

These changes reduced the number of criteria from 381 to about 190. Both the NRC and FEMA believe the updated criteria will provide an appropriate basis for U.S. nuclear power plants and state/local/tribal governments to develop radiological emergency plans and improve emergency preparedness.

Our writers have also been updating and adding several topics to the document’s introduction. The updated intro will address the document’s purpose, scope, and background, as well as the basis for developing emergency plans. New introduction topics include how the document will be used and how the document relates to regulations and other guidance documents. It also includes information on the alternative approaches used to meet NRC and FEMA requirements.

We expect to have the revised preliminary draft ready by the end of May. We’ll make the document available for public review and discussion, including holding another public meeting/webinar in late June at NRC headquarters. We expect to have a formal public comment period on the draft document starting in October 2014.

 

9 responses to “Even the Best Guidance Can Be Updated

  1. Fresh May 27, 2014 at 12:33 pm

    The Declaration of Independence is not a good example. it was a “temporary use” document, and is NOT a part of our current legal system.

    However, referencing the Constitution would be more appropriate.

  2. Dan Hudson May 27, 2014 at 12:20 pm

    You mention in your post “Before starting on the revision, the NRC and FEMA took suggestions from the public and interested groups.” Are there any meeting summaries for those discussions that are publicly available? I think it would be great to see what these groups thought were important criteria for EP programs.

  3. CaptD May 27, 2014 at 12:18 pm

    One area that needs major improvement is the Like-For-Like replacement criteria, since SCE made a mockery of the NRC by claiming that they were doing a Like-For-Like RSG replacement when in fact they were making major design changes that resulting in their 4 new RSG failing soon after installation, a situation that place all of southern California at risk of a nuclear incident and/or nuclear accident!

    Here is a industry document that describes most of the changes that they made while bragging that it was done as “Improving Like-For-Like”:

    https://s3.amazonaws.com/s3.documentcloud.org/documents/347889/col-nrc-tech-paper.pdf

    BTW: Nobody can claim the article is bias since it was published by Nuclear Engineering International…

    • Fresh May 27, 2014 at 1:12 pm

      I know, I can’t believe how badly the NRC was disrespected.

      I am also amazed that charges have not been filed against the spin doctor liars from the plant operators. The equipment supplier should also be implicated.

  4. Public Pit Bull May 27, 2014 at 11:53 am

    If a plant, that is in the backyard of New York City, can be allowed to operate then the NRC really does not have an effective emergency preparedness document for nuclear plants in this country. The point is Indian Point should be decommissioned. That the NRC is considering license extension for this plant means the NRC is beholden to the industry and is not placing public safety first.

    • PJ May 27, 2014 at 10:15 pm

      Dear Public Pit Bull, Please support your statement with why the Indian Point Plant should be decommissioned and how the NRC is not placing public safety first. Blank statements like this are useless in any debate.

      • Public Pit Bull May 28, 2014 at 10:50 am

        Thanks for asking PJ. No nuclear plant should be located anywhere near a major metropolitan area. When millions of people live within the 50-mile emergency planning zone around a nuke plant, how can you possibly ensure their protection in the event of a Chernobyl or Fukushima-type accident?! It is just plain foolishness and playing loose with public safety. Even today a 20-mile radius exclusion zone exists for the area around Chernobyl. A similar Indian Point nuclear plant disaster would require the evacuation of NYC! There is not a more tempting terrorist target than Indian Point. Such a disaster would make 9/11 pale in comparison. In addition did you know PJ that Indian Point is the most susceptible plant in the country to damage from an earthquake. The NRC is well aware of all this and is still not putting public safety first. You talk of blank statements and yet do not recognize that we are playing Russian roulette with 5 bullets in the pistol.

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