ML13108A359
| ML13108A359 | |
| Person / Time | |
|---|---|
| Issue date: | 04/18/2013 |
| From: | Kahler C Office of Nuclear Security and Incident Response |
| To: | Hug M Nuclear Energy Institute |
| Shared Package | |
| ML12293A167 | List: |
| References | |
| Download: ML13108A359 (3) | |
Text
1 Kahler, Carolyn From:
EPFAQ Resource Sent:
Thursday, April 18, 2013 9:46 AM To:
'MTH@nei.org' Cc:
Anderson, Joseph; Kahler, Robert
Subject:
RE: Response from "Submit a Question about Emergency Preparedness" (EPFAQ 2013-005)
Mr. Hug:
Thank you for your recent submission of EPFAQ No. 2013-005, regarding offsite notification performance requirements in 10CFR Part 50, Appendix E, section IV.8E.8.e.
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. 2013-005 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: Thursday, April 11, 2013 11:37 AM 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 Thursday, April 11, 2013 at 11:36:34 relevant-guidance: NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants revision-number: Revision 0 applicable-sections: Section IV.D, Emergency Response Organization Augmentation at Alternative Facility comments: 10CFR Part 50, Appendix E, section IV.8E.8.e states that Alternative Facilities must be capable of performing offsite notifications. Specifically, the regulation states:
2 For nuclear power reactor licensees, an alternative facility (or facilities) that would be accessible even if the site is under threat of or experiencing hostile action, to function as a staging area for augmentation of emergency response staff and collectively having the following characteristics: the capability for communication with the emergency operations facility, control room, and plant security; the capability to perform offsite notifications; and the capability for engineering assessment activities, including damage control team planning and preparation, for use when onsite emergency facilities cannot be safely accessed during hostile action.
This is further explained in NSIR DPR-ISG-01 which states:
For the case where the EOF is located outside the owner-controlled area and the alternative facility is not located in the EOF, the EOF would likely be available to perform the ORO notification function. However, there is no guarantee that the EOF would be available to perform this function during hostile action. Therefore, the alternative facility must be capable of performing offsite notifications.
Under the strictest interpretation, this guidance implies that alternative facilities must be capable of performing offsite notifications, regardless of whether the EOF is available to perform those notifications or not. This interpretation would require some licensees to have the capability for notifications at three facilities (i.e., control room, EOF and the alternative facility).
However, the Federal Register Notice Vol. 76, No. 226, dated November 23, 2011 and 10 CFR Part 50, Appendix E, section IV.E.8.d allow licensees to achieve required capabilities of the alternative facility (or facilities) in the most appropriate manner for their site. This indicates that the capability for offsite notification can be performed at one of multiple designated alternative facilities.
If the EOF is located outside the owner controlled area and is accessible during a Hostile Action Based event, and has the capability to perform offsite notifications within 15 minutes of a change in emergency classification level or issuance of a PAR, then would it be acceptable to designate this responsibility to the EOF. In this situation, the EOF becomes the alternative facility for the offsite communication function.
proposed-solution: For cases where a licensees EOF is located outside the owner controlled area, is a safe distance from the plant, and accessible during a Hostile Action Based event, it is consistent with the Regulation and regulatory guidance for the EOF to perform the alternative facility notification function.
Supporting basis information:
In the strictest interpretation, capability may require some licensees to install redundant ORO notification systems in the alternative facility serving a function of assembly area or, at a minimum, ensure sufficient qualified individuals are available to simultaneously notify OROs in a timely manner. Note that some licensees require notification of up to 7 agencies, as required by their Emergency Plan.
The Federal Register Notice, page 72587, third column for the Rule states that the NRC intends for licensees to use existing facilities that are a safe distance from the plant.
Therefore, the NRC will not codify the equipment that must be present in the alternative facility (or facilities), but rather will allow licensees to achieve the required capabilities of the alternative facility (or facilities) in the most appropriate manner for their site.
originator: Martin Hug organization: Nuclear Energy Institute (NEI) phone: 202.739.8129
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