ML102510555

NEI-99-02 FAQ EOF Participation Rev. 8-13-10, Pre Meeting

ML102510555
Person / Time
Site:	Sequoyah
Issue date:	08/16/2010
From:	Nuclear Energy Institute
To:	Office of Nuclear Security and Incident Response
Shared Package
ML102510243	List: ML102510555 NEI 99-02, NEI-99-02 FAQ EOF Participation Rev. 8-13-10, Pre Meeting NEI 99-02, NEI-99-02 FAQ EOF Participation Rev. 8-16-10, Meeting Markup
References
NEI 99-02, Rev 6
Download: ML102510555 (8)

Text

FAQ TEMPLATE Plant: Tennessee Valley Authority - Sequoyah Date of Event:

10/19/2009 Submittal Date:

XX/XX/2010 Licensee

Contact:

Walt Lee Tel/email: whlee@tva.gov NRC

Contact:

Tel/email:

Performance Indicator: NEI 99-02 (rev. 6) 2.4 Emergency Preparedness Cornerstone Emergency Response Organization Drill Participation and Drill and Exercise Performance Site-Specific FAQ (Appendix D)?

No FAQ requested to become effective quarter following approval.

Question Section NEI 99-02 Guidance needing interpretation (include page and line citation):

Page 50, Lines 3-8 Purpose This indicator tracks the participation of ERO members assigned to fill Key Positions in performance enhancing experiences, and through linkage to the DEP indicator ensures that the risk significant aspects of classification, notification, and PAR development are evaluated and included in the PI process. This indicator measures the percentage of ERO members assigned to fill Key Positions who have participated recently in performance-enhancing experiences such as drills, exercises, or in an actual event.

Page 50, Lines 10 - 13 Indicator Definition The percentage of ERO members assigned to fill Key Positions that have participated in a drill, exercise, or actual event during the previous eight quarters, as measured on the last calendar day of the quarter.

Event or circumstances requiring guidance interpretation:

The event/circumstance principally involves utilities with common EOFs where the functions of EOF Senior Manager, EOF Key Protective Measures and EOF Communicator are assigned to Key Positions that generically support multiple nuclear sites.

Utilities with a common EOF established to support multiple nuclear sites have made Key Position assignments to provide implementation of the three functions mentioned above and described in NEI 99-02 rev 6.

ERO members assigned to each function are grouped and monitored to ensure that each member receives a meaningful opportunity to gain proficiency. This membership is accounted for at the end of each quarter and entered into the ROP process.

Where common EOFs are established supporting multiple sites the EOF, ERO membership is trained, including involvement in a drill and exercise program to ensure that they are fully qualified to respond to each site served by that EOF when emergencies are declared.

In general given this prescribed condition procedures, processes and protocols have been established that have generic application or in words the skill set is similar in application regardless of the nuclear site involved.

Participation Credit is given for these generic key positions and counted (as specified in NEI 99-02) for all nuclear sites served by the EOF when a Key Position member is provided a meaningful opportunity to gain proficiency during any one nuclear site drill or exercise.

Currently, DEP Credit is provided to the nuclear site included in the drill or exercise.

If licensee and NRC resident/region do not agree on the facts and circumstances explain NRC region does not agree with the generic participation credit approached and has specified that participation credit can ONLY be provided to the specific site involved in the drill or exercise.

Potentially relevant existing FAQ numbers NA Response Section Proposed Resolution of FAQ Revise NEI 99-02 to provide clarifying language to more effectively communicate that counting participation credit for NEI 99-02 EOF positions when centralized Emergency Offsite Facilities are utilized or in situations of multiple technologies where common Technical Support Facilities or Operational Support Centers is appropriate as long as:

1) The functions of:

• Classification,

• Protective Action Recommendations (PARs),

• Dose Assessment,

• Emergency Notifications Are performed where applicable similarly for each site serviced by the common facility.

2) The link between Drill and Exercise Performance and Participation are maintained by granting DEP credit from one drill to all sites served by the common facility.

If appropriate, provide proposed rewording of guidance for inclusion in next revision.

[DRILL AND EXERCISE PERFORMANCE]

NEI 99-02 Revision 6, page 45 33 If credit for an opportunity is given in the ERO Drill Participation performance indicator, then 34 that opportunity must be included in the drill/exercise performance indicator. For example, if the 35 communicator performing the entire notification during performance enhancing scenario is an 36 ERO member in a Key Position, then the notification may be considered as an opportunity and, if 37 so, participation credit awarded to the ERO member in the Key Position.

38 DEPopportunitiesperformedinacommonfacilityshallalsobecreditedtoallnuclearsitesservedbythe commonfacility,inadditiontothenuclearsiteparticipatinginthedrillorexercise,thereforemaintainingthe linkbetweenDEPandparticipation.

39 When a performance enhancing experience occurs before an individual is assigned to a Key 40 Position in the ERO, then opportunities for that individual that were identified in advance shall 41 contribute to the Drill/Exercise (DEP) metric at the time the member is assigned to the ERO.

42

[PARTICIPATION]

NEI 99-02 Revision 6, page 50 25 Calculation 26 The participation indicator may include participation in a facility that supports multiple sites or unit technologies and is calculated as follows:

27 NEI 99-02 Revision 6, page 51 1

• Technical Support Center (Personnel may support multiple unit technologies) 2

3

• Senior Manager - Management of plant operations/corporate resources 4

• Key Operations Support 5

• Key Radiological Controls - Radiological effluent and environs monitoring, 6 assessment, and dose projections 7

• Key TSC Communicator-provides offsite (state/local) notification 8

• Key Technical Support 9

10

• Emergency Operations Facility (Personnel may support multiple sites or unit technologies) 11 12

• Senior Manager - Management of corporate resources 13

• Key Protective Measures - Radiological effluent and environs monitoring, 14 assessment, and dose projections 15

• Key EOF Communicator-provides offsite (state/local) notification 16 17

• Operational Support Center (Personnel may support multiple unit technologies) 18 19

• Key OSC Operations Manager NEI 99-02 Revision 6, page 51 41 inspection.

42 Whencommonfacilitykeypositionfunctionsareperformedsimilarlyandaperformanceenhancing experienceoccurs,participationcreditmaybegrantedforthosekeypositionsforallnuclearsitesservedby thecommonfacilityduringanyonenuclearsitedrill.Asimilarapproachmaybetakenforsiteswithmultiple unittechnologies.DEPopportunitiesperformedinthecommonfacilityshallalsobecreditedtoallnuclear sitesservedbythecommonfacility,inadditiontothenuclearsiteparticipatinginthedrillorexercise, thereforemaintainingthelinkbetweenDEPandparticipation.

Processes/activitiesaresimilarwhentheprocesses/activitiesarerelatedtoeachotherforthepurposeof accomplishingthesametask/goal.Examplesofsimilarprocesses/activitiesareprovidedbelow:

ProtectionActionRecommendations(PARs)

ProtectionActionRecommendations,whendevelopedwiththesameprotectiveactionstrategies,aresimilar providedthattheprocessforthedevelopmentoftheprotectiveactionrecommendationsarethesame.For instancethefollowingareexamples;

• Logicflowchartsifusedmaynotbeidenticalbuttheuseoftheflowchartisthesame.

• ProtectiveActionZonesmaynotbeidenticalbuttheprocessthatisusedtoidentifytheactiontaken forthezoneisthesame.

• ImplementationofKIstrategiesmaydifferbasedontheimplementationstrategiesofresponsible authoritiesattheStateand/orLocallevel,buttheprocessthatisusedtodetermineifKIis warrantedisthesame.

• PARdevelopmentdiscussionsprocessesarethesameforeachsiteservicedbytheEOF-i.e.who talkstowhomandwhenthatinteractiontakesplaceisthesame.

DoseAssessment Doseassessmentissimilarwhenmethodologies,applicablecomputerprograms,andmodelsarethesame acrosssitesand/ortechnologiesservedbythecommonfacility.Emergencyreleasedefinitionsarethesame.

TrainingforkeyEROmembersperformingthisfunctiontoincludesitespecificand/ortechnologydifferences ineffluentmonitorsandreleasepathwaysandhowthesedifferencesimpactthedoseassessment.

EmergencyNotifications Theemergencycommunicatorfunctionsaresimilarwhencommonfacilityproceduralprotocolsare performedutilizingacommonproceduralprocess,emergencynotificationandformcontent.Emergency notificationscontactsmaydiffer,butthecommunicatorwillbetrainedonmethodandequipment differencesutilizedtomakenotifications.

Classification EmergencyClassificationprocessesaresimilarwhentheEmergencyActionLevelproceduralprocessesare thesameforallsitesand/ortechnologiesservedbythecommonfacility.TrainingforkeyEROmembers performingthisfunctionshouldincludesitespecificand/ortechnologydifferencesinInitiatingConditions/

EmergencyActionLevelsforsitesservedbythecommonfacility(e.g.,ISFSI,uniquehazards,design considerations,etc.).

LinktoDrillandExercisePerformance CreditforparticipationmaybegrantedacrossafleetormultipletechnologiesthatacommonfacilityERO servesprovidedthatlessonslearnedandcorrectiveactionsfromtheperformanceofkeyEROmembers performingDEPactivitiesaresharedwithorappliedtoallkeyEROmembersofallsitesservedbythe

commonfacilitythroughthecorrectiveactionprogram.ThisapproachensuresthatparticipationbykeyERO membersremainslinkedwithperformanceforthefleet/multipletechnologieswhileretaininganemphasis onthedirectlinkageforthespecificsiteand/ortechnology.Commonfacilitylessonslearned(positiveand negative)shouldbesharedtoensurethatthebenefitsoftheperformanceenhancingexperienceofthekey EROmember(s)areappliedacrossthefleetand/ortechnologiesservedbythecommonfacility.Likewise, anycorrectiveactionsassociatedwithcommonfacilityKeyEROmemberperformance(e.g.trainingor qualificationgaps,proceduredeficiencies,equipmentissues)areappliedacrossthefleetand/ortechnologies servedbycommonfacilities.DEPopportunitiesperformedinthecommonfacilityshallalsobecreditedtoall nuclearsitesservedbythecommonfacility,inadditiontothenuclearsiteparticipatinginthedrillor exercise,thereforemaintainingthelinkbetweenDEPandparticipation.

43 Credit can be granted to Key Positions for ERO Participation for a Security related Drill or 44 Exercise as long as the Key Positions are observed evaluating the need to upgrade to the next