ML072560145
| ML072560145 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/25/2007 |
| From: | David M NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Polson K Nine Mile Point |
| david marshall NRR/DORL 415-1547 | |
| References | |
| TAC MD2989, TAC MD2990 | |
| Download: ML072560145 (17) | |
Text
September 25, 2007 Mr. Keith J. Polson Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNIT NOS. 1 AND 2, PROPOSED SITE EMERGENCY PLAN CHANGE (TAC NOS. MD2989 AND MD2990)
Dear Mr. Polson:
By letter dated August 31, 2006, as supplemented by letters dated April 26, 2007, and August 31, 2007, Nine Mile Point Nuclear Station, LLC submitted proposed changes to the Nine Mile Point Nuclear Station (NMP) Site Emergency Plan (SEP). The proposed changes would eliminate the requirement for augmentation of the on-shift emergency response organization (ERO) personnel with selected ERO staff members within 30 minutes and would require the on-shift ERO to be fully augmented within 60 minutes.
The Nuclear Regulatory Commission (NRC) staff has completed a technical and regulatory review of the proposed NMP SEP changes and supporting documentation. The NRC staff has concluded that incorporation of the proposed changes do not decrease the effectiveness of the NMP SEP and that the NMP SEP, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to Title 10 Part 50 of the Code of Federal Regulations. The basis for our conclusion is contained in the enclosed safety evaluation. In light of our conclusion, no NRC approval is necessary.
Sincerely,
/RA/
Marshall J. David, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410
Enclosure:
Safety Evaluation cc w/encl: See next page
September 25, 2007 Mr. Keith J. Polson Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNIT NOS. 1 AND 2, PROPOSED SITE EMERGENCY PLAN CHANGE (TAC NOS. MD2989 AND MD2990)
Dear Mr. Polson:
By letter dated August 31, 2006, as supplemented by letters dated April 26, 2007, and August 31, 2007, Nine Mile Point Nuclear Station, LLC submitted proposed changes to the Nine Mile Point Nuclear Station (NMP) Site Emergency Plan (SEP). The proposed changes would eliminate the requirement for augmentation of the on-shift emergency response organization (ERO) personnel with selected ERO staff members within 30 minutes and would require the on-shift ERO to be fully augmented within 60 minutes.
The Nuclear Regulatory Commission (NRC) staff has completed a technical and regulatory review of the proposed NMP SEP changes and supporting documentation. The NRC staff has concluded that incorporation of the proposed changes do not decrease the effectiveness of the NMP SEP and that the NMP SEP, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to Title 10 Part 50 of the Code of Federal Regulations. The basis for our conclusion is contained in the enclosed safety evaluation. In light of our conclusion, no NRC approval is necessary.
Sincerely,
/RA/
Marshall J. David, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrDORLLpl1-1 RidsOgcRP MNorris LPLI-1 R/F RidsNrrLASLittle RidsAcrsAcnwMailCenter EWilliamson RidsNrrPMMDavid RidsNsirDprDdepLib RidsRgn1MailCenter Accession No.: ML072560145 NRR-106 OFFICE LPL1-1/PM LPL1-1/LA NSIR/DDEP/LIB/BC*
OGC LPL1-1/BC NAME MDavid SLittle EWeiss EWilliam MKowal DATE 9/20/07 9/20/07 9/18/07 9/21/07 9/25/07
- SE transmitted by memo dated as shown.
OFFICIAL RECORD COPY
Nine Mile Point Nuclear Station cc:
Mr. Michael J. Wallace President Nine Mile Point Nuclear Station, LLC c/o Constellation Energy Group 750 East Pratt Street Baltimore, MD 21202 Mr. Mike Heffley Senior Vice President and Chief Nuclear Officer Constellation Generation Group 1997 Annapolis Exchange Parkway Suite 500 Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 126 Lycoming, NY 13093 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Paul D. Eddy Electric Division NYS Department of Public Service Agency Building 3 Empire State Plaza Albany, NY 12223 Mr. John P. Spath New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mark J. Wetterhahn, Esquire Winston & Strawn 1700 K Street, NW Washington, DC 20006 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Carey W. Fleming, Esquire Senior Counsel Constellation Generation Group, LLC 750 East Pratt Street, 17th Floor Baltimore, MD 21202 Mr. James R. Evans LIPA P.O. Box 129 Lycoming, NY 10393 Mr. Michael Balboni Deputy Secretary for Public Safety State Capitol, Room 229 Albany, NY 12224
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO PROPOSED SITE EMERGENCY PLAN CHANGES NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-220 AND 50-410
1.0 INTRODUCTION
By letter dated August 31, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML062560082), as supplemented by letters dated April 26, 2007 (ADAMS Accession No. ML071280270) and August 31, 2007 (ADAMS Accession No. ML072560015), Nine Mile Point Nuclear Station, LLC (the licensee) submitted proposed changes to the Nine Mile Point Nuclear Station (NMP) Site Emergency Plan (SEP). The proposed changes would eliminate the requirement for augmentation of the on-shift emergency response organization (ERO) personnel with selected ERO staff members within 30 minutes and would require the on-shift ERO to be fully augmented within 60 minutes. The licensees review of the proposed changes concluded that the revised NMP SEP would continue to meet the planning standards of Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b) and that no decrease in effectiveness of the SEP would occur.
2.0 REGULATORY EVALUATION
The applicable regulations and guidance that the licensee must meet for the emergency plans are as follows.
2.1 Regulations Applicable parts of 10 CFR:
10 CFR 50.47(b)(1) states, in part, "... each principal response organization has staff to respond and to augment its initial response on a continuous basis."
10 CFR 50.47(b)(2) states, in part, "... adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available..."
10 CFR Part 50, Appendix E, Section IV, Part A, Organization, states, in part, The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization 2.2 Guidance Applicable regulatory guidance:
Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 4, states, in part, "The criteria and recommendations contained in Revision 1 of NUREG-0654/FEMA [Federal Emergency Management Agency]-REP-1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47(b) that must be met in onsite and offsite emergency response plans... Licensees and applicants may propose means other than those specified by the provisions... for meeting applicable regulations."
Revision 1 to NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"Section II.B.5 states, in part, Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.
NRC Regulatory Issue Summary (RIS) 2005-02, "Clarifying the Process for Making Emergency Plan Changes," February 14, 2005, provides guidance to licensees making changes to their emergency plans.
3.0 TECHNICAL EVALUATION
The proposed changes to the NMP SEP were reviewed by the licensee in accordance with 10 CFR 50.54(q) considering the requirements of 10 CFR 50.47, Appendix E to 10 CFR Part 50, and other applicable NRC guidance (e.g., RIS 2005-02). The proposed changes would eliminate the requirement for augmentation of the on-shift ERO personnel with selected ERO staff members within 30 minutes and would require the on-shift ERO be fully augmented within 60 minutes. In its letter of August 31, 2006, the licensee stated that this proposed change was requested to assure that ERO augmentation occurs within requisite time frames (considering increased flexibility of normal licensee working hours), to provide a more effective span of control for the on-shift Emergency Director, and to assure that more consistent oversight and direction is provided to the augmented ERO staff performing assessment and mitigative actions.
The NRC staff's evaluation is based on the proposed changes to the NMP SEP provided in the licensee's letter dated August 31, 2006, as supplemented by letters dated April 26, 2007, and August 31, 2007. The specific changes involve Section 5.2, On-site Emergency Response Organization, of the NMP SEP, Revision 15, which was approved by the Nuclear Regulatory Commission (NRC) staff in NUREG-1047 Safety Evaluation Report Related to Operation of Nine Mile Point Nuclear Station, Unit 2, Supplement 3, Section 13.3.4, dated July 1986.
NRC-Approved SEP Wording During off-hours, the Station Shift Supervisor uses a notification roster to ensure that personnel to fill key positions within the emergency organization can be promptly notified, and to allow them to respond within 30 to 60 minutes, after notification of an emergency.
Figure 5.3 presents, in tabular form, the available personnel on-shift and those key positions as minimum, required to augment the On-site Emergency Response Organization within 30 to 60 minutes after notification.
NMP Proposed Wording All emergency facilities will be staffed within 60 minutes of notification.
The NRC staff has reviewed the technical and regulatory analysis in support of the proposed changes. As part of this review, the NRC staff specifically looked to determine whether the on-shift staff positions would be able to support actions to safely shutdown the plant, place it in a safe condition, or respond to an event that would require Operations, ERO, and Fire Brigade support, simultaneously, and still meet the original intent of the NRC-approved NMP SEP, Revision 15. This is in order to fully evaluate the impact these proposed changes could have on existing and augmented staff to ensure that competing priorities do not occur which could jeopardize required actions. As described in the following analysis, these changes were evaluated in light of the technological advances implemented since the issuance of NUREG-0654/FEMA-REP-1 in 1980, improved procedures, changes in NRC requirements, and efficiencies in the licensee's staff responsibilities and duties.
3.1 Major Functional Areas Plant Operations and Assessment of Operational Aspects The proposed changes do not adversely impact on-shift staffing. NUREG-0654/FEMA-REP-1, Table B-1 does not designate staff augmentation goals for this major function area.
Emergency Direction and Control NUREG-0654/FEMA-REP-1, Table B-1 guidance indicates that the shift technical advisor, shift supervisor or designated facility manager should be assigned this function as a collateral duty, where responsibility for overall direction of facility response may be transferred when all centers are fully manned. NMP, under Footnote 2 to Table 5.1, identifies that the shift manager will initially perform this on-shift function until relieved. While NMP Table 5.1 currently designates the Technical Support Center (TSC) Manager and Emergency Operations Facility (EOF)
Manager as being available in 60 minutes, Table B-1 of NUREG-0654/FEMA-REP-1 does not designate an augmentation goal for this direction and control function.
Notification / Communication In accordance with Table B-1 of NUREG-0654/FEMA-REP-1, on-shift staffing should consist of one position (who, per footnote ****, may be performed as a collateral duty by the engineering aide to the shift supervisor), and one "30-minute" and one "60-minute" responder. NMP, under Footnote 3 to Table 5.1, identifies that this position is initially assumed by one of the Auxiliary or Radwaste Operators. The approved NMP Table 5.1 requires one communicator to be assigned on-shift with the capability to augment one communicator in 30 minutes and an additional two communicators in 60 minutes. The proposed NMP Table 5.1 requires one communicator to be assigned on-shift with the capability to augment three communicators in 60 minutes.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
NMP procedure GAP-OPS-01, Conduct of Operations, provides the details of on-shift staffing requirements. This specifically requires that a communication aide (from each unit) be assigned from among the auxiliary operators and this individual shall have no other emergency duties.
The communications aide has advanced communications capabilities available such as the radiological emergency communication system (RECS), which permits a single telephone call to reach all required off-site organizations simultaneously.
Communications with the NRC are over dedicated telephone lines provided for and maintained by the NRC (via the Emergency Notification System (ENS) Line). The communications aide is relieved of communications with Federal agencies (NRC) by the ENS Communicator and by the Health Physics Network (HPN) Line Communicator in the TSC. The communications aide is further relieved of communications responsibilities with State and local agencies by the Communication Coordinator located in the EOF. All of these augmented ERO positions are required to respond within 60 minutes of notification.
Based on the on-shift staffing complement designated in NMP Table 5.1 for notifications /
communications and the advanced communications capabilities available, the NRC staff believes that adequate on-shift resources exist to support offsite notifications / communications within 60 minutes of event classification, prior to being relieved by the TSC or EOF. Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
Radiological Accident Assessment and Support of Operational Accident Assessment a.
The approved NMP Table 5.1 indicates that one individual with senior health physics (HP) expertise should be available in 30 minutes to perform the major task of on-site dose assessment, and identifies the Radiological Assessment Manager as available within 30 minutes. The proposed NMP Table 5.1 identifies the augmentation time for on-site dose assessment as 60 minutes.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
The function of on-site radiological assessment is to review radiological conditions on-site using data from available instrumentation, assess the impact of changing radiological conditions on emergency classification, assist in accident assessment based upon those changing radiological conditions, and recommend appropriate on-site protective measures.
Classification is performed by the Shift Manager using NMP procedures EPIP-EPP-01, Classification of Emergency Conditions at Unit 1, and EPIP-EPP-02, Classification of Emergency Conditions at Unit 2, for classification of emergency conditions at NMP Unit No. 1 and Unit No. 2, respectively, utilizing the NUMARC NESP-007 emergency classification methodology. This methodology uses readily available and easily recognized plant instrumentation, combined with event and symptom based emergency action levels to determine the appropriate emergency classification. Though off-site and on-site surveys would result in additional sources of information, such as direct radiation measurements that could be directly applied to emergency classification, it is more likely that other events, system failures or plant instrumentation would lead to the appropriate emergency classification. The on-shift Radiation Protection (RP) Technician reports to the control room upon notification of any declared emergency to provide radiological assessment support. The Control Room Supervisor uses flowcharted symptom based emergency operating procedures (EOPs). These procedures eliminate the need for specific accident assessment.
The operating crew performs actions based on symptoms that are described in the EOPs, not based upon what type of accident.
The Shift Manager uses flowcharts contained within NMP procedure EPIP-EPP-18, Activation and Direction of the Emergency Plans, which contains the decision making processes by which on-site protective measures are directed.
The information needed to accomplish this is simple and deterministic in nature and allows for rapid decision making using readily available information by the Shift Manager/Emergency Director.
Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
b.
NUREG-0654/FEMA-REP-1, Table B-1 guidance for in-plant surveys states that one HP technician should be assigned on-shift with the capability to augment one HP technician in 30 minutes and an additional HP technician in 60 minutes. The approved NMP Table 5.1 requires one RP technician to be assigned on-shift with the capability to augment one RP technician in 30 minutes and an additional RP technician in 60 minutes. The proposed NMP Table 5.1 requires one RP technician to be assigned on-shift with the capability to augment two RP technicians in 60 minutes.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
Personnel accessing the radiologically controlled areas (RCA) at NMP are required by procedure to obtain electronic alarming dosimetry (EAD) prior to entry. The same EAD is also used as a key to unlock turnstiles to gain access to the RCA. Radiation work permits (RWPs) establish the necessary preset warnings/alarms associated with the EAD. Specific emergency RWPs have also been developed for use during a declared emergency, which automatically provide the EAD with emergency dose and dose rate alarms. This assures that the person dispatched to the in-plant areas to perform any function during a declared emergency will be afforded ample warning/alarm prior to exceeding his/her allowed dose or dose rate. Also, damage control teams are briefed prior to dispatch regarding radiological conditions. Thus, personnel responding to emergencies in a high radiation area will be knowledgeable of dose rates in the area without the need to send Radiation Personnel into the plant with the teams, in accordance with Technical Specification requirements. In addition, in the event that additional RP assistance is needed, the on-shift RP technician at the unaffected unit may also be called upon for this function.
Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
c.
NUREG-0654/FEMA-REP-1, Table B-1 guidance for chemistry / radio-chemistry indicates that one rad/chem technician should be assigned on-shift with the capability to augment one rad/chem technician in 60 minutes. The approved NMP Table 5.1 requires one chemistry technician on-shift with the capability to augment one chemistry technician in 30 minutes and an additional one available within 60 minutes. The proposed NMP Table 5.1 requires one chemistry technician to be assigned on-shift with the capability to augment two chemistry technicians in 60 minutes.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
The value of reactor water chemistry sample analysis decreases significantly with the severity of a declared emergency. Samples may be obtained prior to, or early into, an emergency and may even drive emergency classification.
However, once emergency classification is made, the value of this type of analysis diminishes greatly. This conclusion is consistent with the NRC staff safety evaluations for Nine Mile Point Unit No. 1 License Amendment No. 174 (issued on August 26, 2002), and Nine Mile Point Unit No. 2 License Amendment No. 106 (issued on August 9, 2002). These license amendments relaxed the requirements for the Post Accident Sampling System. In those safety evaluations, the NRC staff agreed that sampling of radioisotopes is not required to support emergency response decision making during the initial phases of an accident. Thus, the chemistry technician will be able to devote his attention to emergency duties.
The activities of the chemistry technician during an emergency as the dose assessment advisor are either automated (specifically, obtaining meteorological data and release rate assessments) or deterministic and can be performed rapidly (specifically, developing of protective action recommendations).
In the event that a rapid dose assessment is needed, the on-shift chemistry technician at the unaffected unit may be called upon to perform either the normal or emergency functions of the affected unit chemistry technician. NMP chemistry technicians are cross-trained on both units.
Technological advances implemented since the issuance of NUREG-0654/FEMA-REP-1 (i.e., severe accident management guidelines, core damage assessment methodologies) have reduced the need for prompt augmentation of radio-chemistry capabilities. In addition, the relaxation of the regulatory requirement for post-accident sampling systems in technical specifications has reduced the on-shift chemistry staff burden. Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
d.
NUREG-0654/FEMA-REP-1, Table B-1 guidance for offsite and onsite (out-of-plant) surveys does not designate on-shift staffing for these major tasks, but rather outlines the capability to augment staffing by three HP technicians within 30 minutes and by three HP technicians within 60 minutes. As such, the approved NMP Table 5.1 does not require on-shift staffing for these functions, but provides for staff augmentation of two RP technicians within 30 minutes and four RP technicians within 60 minutes. The proposed NMP Table 5.1 does not designate on-shift staffing with the capability to augment six RP technicians in 60 minutes.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
Dose Assessment - NMP procedure EPIP-EPP-08, Off-site Dose Assessment and Protective Action Recommendations, utilizes the results of off-site surveys in the dose assessment process, but only after the EOF is activated and the dose assessment staff is fully augmented. This procedure is consistent with NUREG-0654, Supplement 3, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants - Criteria for Protective Action Recommendations for Severe Accidents," dated July 1996, which details rapid, deterministic methods of protective action development. The existing process allows for an appropriately detailed briefing, appropriate direction, and full analysis of the survey results. Specific data obtained from off-site surveys is not typically incorporated into the on-shift dose assessment process, following the deterministic method of protective action formulation required by and described in NUREG-0654, Supplement 3. In addition, if needed to perform actions outside of the control room (e.g., downwind monitoring), the Shift Manager /
Emergency Director may call upon the on-shift RP technician at the unaffected unit or the RP technician at the adjoining J. A. FitzPatrick plant (in accordance with a letter of agreement).
Protective Action - Flowcharts contained within NMP procedure EPIP-EPP-18, Activation and Direction of Emergency Plans, contain the decision making process by which on-site protective actions are determined. The information needed to accomplish this is simple and deterministic in nature, which allows for rapid decision making using readily available information. The use of more quantitative data, such as that which would be obtained from off-site or on-site survey teams, would not provide early commensurate benefit until the ERO is fully staffed.
Emergency Classification - NMP procedures EPIP-EPP-01 and EPIP-EPP-02 for classification of emergency conditions at NMP Unit No. 1 and Unit No. 2, respectively, were developed utilizing the NUMARC NESP-007 emergency classification methodology. This methodology uses readily available and easily recognized plant instrumentation, combined with event and symptom based emergency action levels to determine the appropriate emergency classification. Though off-site and on-site surveys would result in additional sources of information, such as direct radiation measurements that could be directly applied to emergency classification, it is more likely that other events, system failures or plant instrumentation would lead to the appropriate emergency classification.
Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
Plant System Engineering, Repair and Corrective Actions a.
NUREG-0654/FEMA-REP-1, Table B-1 guidance for technical support states that one Shift Technical Advisor (STA) be on-shift and that core/thermal hydraulics expertise be available in 30 minutes. The approved NMP Table 5.1 requires one STA to be on-shift and that core/thermal hydraulics expertise be available in 30 minutes. The proposed NMP Table 5.1 requires one STA to be on-shift and that core/thermal hydraulics expertise be available in 60 minutes.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
The function of the core/thermal hydraulics expertise responder is to provide confirmation of adequacy of core cooling, maintenance of coolable core geometry, and to provide that actual plant response to the event is as expected.
The STA is a function, as provided for in NUREG-0654, Table B-1 (the double-asterisked note), that can be performed by personnel on shift who have other functions. NMP procedure GAP-OPS-01, Conduct of Operations, requires each unit to have a Shift Manager (Senior Reactor Operator (SRO) licensed) that is qualified as an Emergency Director and maintains oversight of plant operations; a Control Room Supervisor (SRO licensed) who directs the actions of the licensed and non-licensed operators in an emergency, including the EOPs; and a qualified STA to assure that plant response is as expected and that the core remains in a coolable geometry.
The use of flowcharted, symptom-based emergency operating procedures, severe accident procedures, and a computerized/automated core management and calculation routine (3-D Monicore), combined with current shift staffing, provide for adequate functional oversight to assure that core thermal hydraulic limits are not exceeded and that core coolable geometry is maintained.
Based on the capabilities of various on-shift personnel to recognize core damage indications, and technological advances since the implementation of NUREG-0654/FEMA-REP-1, Revision 1 (i.e., Severe Accident Mitigation Guidelines, core damage assessment methodology, etc.), the NRC staff believes that an adequate on-shift expertise exists to perform the core/thermal hydraulic function within 60 minutes of event classification until emergency response facilities are activated.
Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
b.
NUREG-0654/FEMA-REP-1, Table B-1 guidance for repair and corrective actions states that two individuals, one with mechanical maintenance / rad waste operator experience and one with electrical maintenance / instrument and controls (I&C) experience, should be designated on-shift, but may be provided by shift personnel assigned other functions.
In addition, Table B-1 guidance outlines addition of one Mechanical Maintenance staff, one Electrical Maintenance staff and one I&C staff to be augmented within 30 and 60 minutes, respectively. The approved NMP Table 5.1 identifies two individuals, filled by on-shift equipment operators, who will perform repair and corrective actions as necessary as a collateral duty prior to staff augmentation of one Mechanical Maintenance staff, one Electrical Maintenance staff and one I&C staff in 30 minutes and an additional one each, respectively, in 60 minutes. The proposed NMP Table 5.1 identifies two individuals, filled by on-shift equipment operators, who will perform repair and corrective actions as necessary as a collateral duty prior to staff augmentation of two with Mechanical Maintenance experience, two with Electrical Maintenance experience and one I&C Staff in 60 minutes.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
The function of these positions during the time frame in question is to provide for minor or limited scope damage repair and corrective functions such as:
Mechanical - Identification and operation of faulty valves, clogged filters, packing and/or seal adjustments, and/or troubleshooting.
Electrical - Identification and correction of tripped breakers and overloads, and/or hands off troubleshooting.
I&C - Identification and correction of controller and set point mal-adjustment, calibration, and surveillance necessary for accident mitigation, and / or hands off troubleshooting.
NMP procedure GAP-OPS-01 requires that shift staffing consist of two non-licensed operators (NLOs) who are required to have the capability to perform basic corrective action functions such as detailed above (licensed operators may also fill this role). These two NLOs are required by this same procedure to have no other emergency planning duties (such as fire brigade or communications aide). All required emergency mechanical, electrical, and I&C maintenance functions that can likely be accomplished early in the emergency (within 30 minutes following declaration) are accommodated within the requisite time frames using on-shift resources, and any anticipated tasks can be handled by those resources. Thus, the addition of these augmented responders does not substantially add to the capability to perform corrective actions prior to activation of on-site facilities.
Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
Protective Actions (In-Plant)
NUREG-0654/FEMA-REP-1, Table B-1 guidance for protective actions (in-plant) indicates that two HP technicians should be assigned on-shift to support radiation protection activities.
However, these HP technicians may be provided by shift personnel assigned other functions and this staff will be augmented with two additional HP technicians in 30 minutes and two additional HP technicians in 60 minutes. The approved NMP Table 5.1 assigns one RP technician and one chemistry technician on-shift, and augments with one technician in 30 minutes and three more technicians in 60 minutes. The proposed NMP Table 5.1 maintains the on-shift staffing and augments it with four technicians in 60 minutes.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
The function of the additional resources is to provide radiation protection oversight of personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue, first aid, fire fighting and personnel monitoring.
Personnel accessing the RCA at NMP are required by procedure to obtain an EAD prior to entry. The same EAD is also used as a key to unlock turnstiles to gain access to the RCA. RWPs establish the necessary preset warnings/alarms associated with the EAD. Operations personnel typically sign into their assigned RWP at the beginning of their assigned shift and sign out after turnover at the end of their shift. This permits rapid ingress / egress to the RCA if the need arises. On-shift personnel are able to access the RCA of the station using the EADs, normal RWPs and emergency RWPs (for damage control and repair, search and rescue, first aid and fire fighting). Specific emergency RWPs have also been developed for use during a declared emergency, which automatically provide the EAD with emergency dose and dose rate alarms. This assures that the person dispatched to the in-plant areas to perform any function during a declared emergency will be afforded ample warning / alarm prior to exceeding his / her allowed dose or dose rate. Also, damage control teams are briefed prior to dispatch regarding radiological conditions. Thus, personnel responding to emergencies in a high radiation area will be knowledgeable of dose rates in the area without the need to send Radiation Personnel into the plant with the teams, in accordance with Technical Specification requirements. In addition, in the event that additional RP assistance is needed, the on-shift RP technician at the unaffected unit may also be called upon for this function.
Off-site agency personnel (such as fire department and medical personnel) responding to NMP are issued dosimetry by the security force members assigned to vehicle access as they enter the site through the vehicle security access. These responders are trained to read their dosimeters and respond to various dose and dose rate limits without intervention of NMP personnel.
Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
Site Access Control and Personnel Accountability Site access control and personnel accountability activities are an on-shift staff duty in accordance with NUREG-0654/FEMA-REP-1, Table B-1 guidance. The approved NMP Table 5.1 indicates an individual on-shift (who may be provide by shift personnel assigned other functions) with augmentation of one additional person within 30 minutes and 60 minutes, respectively. The proposed change maintains the individual on-shift, eliminates the 30-minute responder and maintains the 60-minute responder.
As justification for the proposed change to increase augmentation time for selected ERO staff members to 60 minutes, the licensee, in Attachment (1) to its letter dated August 31, 2006, and in its two supplemental letters, provided the following information:
NMP utilizes a computerized accountability system. Personnel are required to card-in to gain access to the protected area. By carding in, each person is then logged into a computer data base, which is maintained by the security computer. Upon initiation of accountability, all personnel are trained and required to card-in to an accountability card reader. These card readers are located in multiple locations throughout the protected area. The Security Site Supervisor then initiates the computer protocol for accountability, which instructs the computer to compare the list of personnel within the protected area to those that have carded into the accountability card readers and print out the missing personnel. This list is then reported to the Shift Manager / Emergency Director for initiation of search and rescue if needed. In accordance with NUREG-0654, the process to identify the missing personnel must be completed within 30 minutes and maintained thereafter. The augmentation of one person to aid in or perform this function does not affect the ability to perform the function within the required time frame.
Therefore, the proposed change to the ERO augmentation (response) time continues to meet the intent of the NRC-approved SEP, and continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
4.0 CONCLUSION
The NRC staff has performed a technical and regulatory review of the proposed changes to the NMP SEP in its letter dated August 31, 2006, as supplemented by letters dated April 26, 2007, and August 31, 2007. The NRC staff has determined that incorporation of the proposed changes do not decrease the effectiveness of the NMP SEP and the SEP, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
5.0 REFERENCES
1.
NMP Letter, "Proposed Site Emergency Plan Change Regarding 30 Minute Augmentation of the Emergency Response Organization," dated August 31, 2006.
(ADAMS Accession No. ML062560082) 2.
NMP Letter, "Proposed Site Emergency Plan Change Regarding 30 Minute Augmentation of the Emergency Response Organization - Response to NRC Request for Additional Information," dated April 26, 2007. (ADAMS Accession No. ML071280270) 3.
NMP Letter, "Proposed Site Emergency Plan Change Regarding 30 Minute Augmentation of the Emergency Response Organization - Response to NRC Request for Additional Information," dated August 31, 2007. (ADAMS Accession No. ML072560015) 4.
NUREG-0654/FEMA Rep-1, Revision 1, Supplement 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980. (ADAMS Accession No. ML040420012) 5.
NUREG-0654/FEMA Rep-1, Revision 1, Supplement 3, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants - Criteria for Protective Action Recommendations for Severe Accidents," dated July 1996. (ADAMS Accession No. ML051120480) 6.
Nuclear Utilities Management Council (NUMARC) document, entitled NESP-007, Methodology for Development of Emergency Action Levels, (Revision 2, January 1992).
(ADAMS Accession No. ML041120174) 7.
NRC Regulatory Issue Summary 2005-02, Clarifying the Process for Making Emergency Plan Changes. (ADAMS Accession No. ML042580404)
Principal Contributor: Michael Norris Date: September 25, 2007