ML12291A768
| ML12291A768 | |
| Person / Time | |
|---|---|
| Issue date: | 09/06/2012 |
| From: | Kahler C Office of Nuclear Security and Incident Response |
| To: | Nuclear Energy Institute |
| Kahler, Carolyn NSIR/DPR/ORLOB 415-0705 | |
| Shared Package | |
| ML12258A107 | List: |
| References | |
| EPFAQ 2012-004 | |
| Download: ML12291A768 (2) | |
Text
Kahler, Carolyn From: EPFAQ Resource Sent: Thursday, September 06, 2012 4:15 PM To: 'MTH@nei.org'
Subject:
Acceptance of EPFAQ No. 2012-004
Dear Mr. Hug:
Thank you for your recent submission of EPFAQ No. 2012-004, Appendix E to Part 50,Section IV.A.9 requires by December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.
At this time, your comment has been accepted for review by appropriate U.S. NRC staff. You will be notified via email when EPFAQ No. 2012-004 has been added to www.regulations.gov for a 30-day public comment period. At that time, the ADAMS accession number and Federal Register Notice docket number will be provided for your reference.
To track the status of your submitted question, please visit the website http://www.nrc.gov/about-nrc/emerg-preparedness/faq/faq-contactus.html#status. If you have any questions regarding submitting an EP FAQ, please feel free to contact me at carolyn.kahler@nrc.gov or 301-415-0705.
Sincerely, Carolyn J. Kahler Communications and Outreach Office of Nuclear Security and Incident Response US Nuclear Regulatory Commission Phone: 301-415-0705 Email: Carolyn.Kahler@nrc.gov
Original Message-----
From: MTH@nei.org [1]
Sent: Monday, August 06, 2012 2:15 PM To: EPFAQ Resource
Subject:
Response from "Submit a Question about Emergency Preparedness" Below is the result of your feedback form. It was submitted by (MTH@nei.org) on Monday, August 06, 2012 at 14:15:00 relevant-guidance: Appendix E to Part 50,Section I.5 and IV.A.9 Federal Register / Vol. 76, No. 226 / Wednesday, November 23, 2011, page 72579,Section IV, Section-by-Section Analysis revision-number: NA applicable-sections: NA 1
comments: Appendix E to Part 50,Section IV.A.9 requires by December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.
An applicant for an early site permit under Part 52 that chooses to propose either major features of an, or a complete and integrated, emergency plan (§ 52.17(b)(2)), or a combined license under Part 52 (§ 52.79(a)(21)) whose application is docketed before December 23, 2011 may choose to defer compliance with this rule until December 31, 2013.
Question: How may an applicant comply with the A.9 requirement by December 31, 2013 when:
- There is not yet a qualified on-shift staff?
- Job task analysis for the on-shift staff are not completed?
- A simulator is not yet available to perform time-motion studies?
proposed-solution: Federal Register / Vol. 76, No. 226 / Wednesday, November 23, 2011, page 72579,Section IV, Section-by-Section Analysis states:
An applicant that defers compliance with this rule is expected to implement this rule under the same schedule as it would implement EP requirements in the absence of this rule. This means that this rule does not require any immediate implementation actions on the part of any applicant, but rather shall be implemented after receipt of a combined license, and under the licensees schedule for completing EP-related requirements (e.g., through completion of EP-related Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC)). (End of Federal Register)
Therefore, an applicant that chooses to defer compliance shall request to:
- Amend the combined license or early site permit no later than December 31, 2013.
- Revise its combined license or early site permit application no later than December 31, 2013 (if the applicant has not received a combined license or early site permit before December 31, 2013).
Proposed Solution: The amendment or revision to the combined license or early site permit shall commit to performing the On-Shift Staffing Analysis using NEI 10-05, Assessment of On-Shift ERO Staffing and Capabilities, Revision 0, shall specify when the NEI 10-05 analysis will be performed during implementation of other EP-related requirements and will be tracked by a license condition (same process used for implementation of Emergency Action Levels using NEI 07-01).
originator: Martin Hug organization: Nuclear Energy Institute (NEI) phone: 202.739.8129 2