ML15286A005
| ML15286A005 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/06/2015 |
| From: | Mahesh Chawla Plant Licensing Branch III |
| To: | Cross W Florida Power & Light Co |
| References | |
| Download: ML15286A005 (10) | |
Text
NRR-PMDAPEm Resource From: Chawla, Mahesh Sent: Tuesday, October 06, 2015 2:23 PM To: Cross, William (WILLIAM.CROSS@fpl.com); michael.millen@nexteraenergy.com; Mrozinsky, Richard (Richard.Mrozinsky@nexteraenergy.com)
Cc: Pelton, David; Anderson, Joseph; Norris, Michael; Wasem, Michael
Subject:
Request for Additional Information - Point Beach LAR 277 - Revision to Staff Augmentation Times in the Point Beach Nuclear Plant Emergency Plan Attachments: Point Beach ERO Staffing LAR - Draft RAIs_10-05-15.docx By letter dated June 12, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15166A042), and supplemented by letters dated August 11, and August 28, 2015, (ADAMS) Accession Numbers ML15223B277 and ML15240A017, respectively), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted a license amendment for Point Beach Nuclear Plant (PBNP), Units 1 and 2. The proposed amendment would revise the PNBP Emergency Plan, to increase the staff augmentation times for Emergency Response Organization (ERO) response functions.
The NRC staff has reviewed the information provided in your application and subsequent supplements. In order to complete our review, please provide your response to the attached request for additional information. Please arrange a teleconference with the NRC staff to discuss the requested information at your earliest possible. Thanks Mahesh Chawla Project Manager Phone: 301-415-8371 Fax: 301-415-1222 mahesh.chawla@nrc.gov 1
Hearing Identifier: NRR_PMDA Email Number: 2446 Mail Envelope Properties (Mahesh.Chawla@nrc.gov20151006142300)
Subject:
Request for Additional Information - Point Beach LAR 277 - Revision to Staff Augmentation Times in the Point Beach Nuclear Plant Emergency Plan Sent Date: 10/6/2015 2:23:13 PM Received Date: 10/6/2015 2:23:00 PM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:
"Pelton, David" <David.Pelton@nrc.gov>
Tracking Status: None "Anderson, Joseph" <Joseph.Anderson@nrc.gov>
Tracking Status: None "Norris, Michael" <Michael.Norris@nrc.gov>
Tracking Status: None "Wasem, Michael" <Michael.Wasem@nrc.gov>
Tracking Status: None "Cross, William (WILLIAM.CROSS@fpl.com)" <WILLIAM.CROSS@fpl.com>
Tracking Status: None "michael.millen@nexteraenergy.com" <michael.millen@nexteraenergy.com>
Tracking Status: None "Mrozinsky, Richard (Richard.Mrozinsky@nexteraenergy.com)"
<Richard.Mrozinsky@nexteraenergy.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 1012 10/6/2015 2:23:00 PM Point Beach ERO Staffing LAR - Draft RAIs_10-05-15.docx 46451 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY PLAN CHANGE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301 By letter dated June 12, 2015, and supplemented by letters dated August 11 and August 28, 2015, (Agencywide Documents Access and Management System (ADAMS) Accession Numbers ML15166A042, ML15223B277 and ML15240A017, respectively), NextEra Energy Point Beach, LLC (NextEra) is requesting an amendment to Renewed Facility Operating Licenses DPR-24 and DPR-27 for the Point Beach Nuclear Plant (PBNP) Units 1 and 2, respectively. NextEra proposes to revise the Point Beach Emergency Plan, to increase the staff augmentation times for Emergency Response Organization (ERO) response functions.
Additional changes include relocation of the Emergency Director and Emergency Action Level Monitor positions, and the addition of an Assistant Emergency Operations Facility Manager position.
The staff reviewed the referenced NRC safety evaluation report (SER) dated June 10, 1983 (ADAMS Legacy Accession No. 8306130431), as part of its evaluation of the proposed changes. As referenced in the SER, the staff also reviewed letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), with a specific focus on Attachment 2 that provided a comparison of the PBNP on-shift staffing and augmentation to Table B-1 (Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies) of Revision 1 to NUREG-0654/FEMA-REP-1 (NUREG-0654), Criteria for Preparation and Evaluation of Radiological Emergency response Plans and Preparedness in Support of Nuclear Power Plants.
The staff identified two additional approvals for Technical Specification changes to Operations staffing, License Amendments No. 91 and 95, dated April 8, 1985 (ADAMS Accession No. ML021930508), and License Amendments No. 190 and 195, dated August 11, 1999 (ADAMS Accession No. ML021980126). These are the only additional NRC approvals since the original SER.
Additionally, by letter dated January 25, 1991 (ADAMS Legacy Accession No. 9101290140),
Wisconsin Electric Power Company informed the NRC that the Duty and Call Superintendents would no longer reside within the 15 miles of the site as discussed in the February 18, 1982 letter. The NRC acknowledge this in letter dated March 21, 1991 (ADAMS Legacy Accession No. 9104020370).
The requests for additional information (RAIs) listed below, are needed to support NRC staffs continued technical review of the proposed Emergency Plan change.
DRAFT
RAI-PBNP-1:
Page 4 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides that the current Emergency Plan identifies the Emergency Director (EOF) as being responsible for State, local and Federal notification. It further provides that the new position of the Emergency Director in the Technical Support Center (TSC) will be assigned the notification function. Section 40.1.1 on page 23 of 30 of Appendix A to the original application provides that the Emergency Director is only responsible for NRC (ENS)
Communications. Please explain this discrepancy, or revise as appropriate to address conflicting statements.
RAI-PBNP-2:
Page 4 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following:
The proposed change includes transmission of the notification information to the State and County by the Security Shift Supervisor position. This position is maintained as an on-shift security department resource dedicated to this function. Upon ERO activation, the Security Shift Supervisor would report to the TSC and perform this function until it is transitioned to the EOF within 90 minutes from event classification. This change allows the notification function to transition from the Control Room to the TSC in the same timeframe (60 minutes) as the function transitions from the Control Room to the EOF under the current Emergency Plan and so maintains the capability for the major task of state/local notification.
Table 5.1 of the proposed and current plan provides that the function of State and local communication is performed on-shift by the Security Shift Supervisor.
EPIP 1.1, Course of Actions, states in step 5.2:
Direct the Security Shift Supervisor to report to the Control Room.
Please explain the process for transition of notifications from the Control Room to the TSC at 60 minutes.
RAI-PBNP-3:
Section 3.1.10 of EP 5.0, Organization Control of Emergencies, provides the following:
A Security Shift Supervisor (SSS) is available to perform state and local notifications.
During emergency situations, the SSS reports to the Security Coordinator in the TSC.
Has this collateral duty been evaluated against Commission Order EA-02-026? Additionally, is there Emergency Plan guidance to identify an alternate individual to serve as a communicator if the SSS is not available during a hostile action-based event?
DRAFT
RAI-PBNP-4:
Page 7 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following:
In the current Emergency Plan, dose assessment is completed by the on-shift Operations Senior Reactor Operator (SRO) in the unaffected Unit and the task is transitioned to Dose/PAR Coordinator in the EOF while additional support for this major task is provided by the Rad/Chem Coordinator in the TSC.
In the proposed Plan, the Rad/Chem Coordinator response would be extended from 30 minutes to a 60 minute responder and the Dose/PAR Coordinator response would be extended from 30 to 90 minutes. The augmentation change for the Rad/Chem Coordinator position in the TSC would result in the performance of the dose assessment task on-shift for an additional 30 minutes. The completion of on-shift dose assessment activities was evaluated during the On-Shift Staffing Analysis. The analysis showed that an onshift SRO was available to complete dose assessment in the scenarios that included a radiological release for up to 60 minutes.
Please provide evidence, that during an event affecting both units, one of the on-shift SROs would be able to perform the offsite dose assessment function for an additional 30 minutes as described in the proposed Plan.
RAI-PBNP-5:
Page 8 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for the Offsite Surveys Major Task:
The current Emergency Plan maintains the one on-shift RP Technician as well as the 60 minute augmentation time at the Alert or higher classification for the offsite survey teams. The Dose/PAR Coordinator position, a 30 minute responder in the EOF is responsible for providing field monitoring team oversight in conjunction with the Offsite Radiation Protection Facility (OSRPF) Coordinator, a 60 minute responder in the OSRPF.
In the proposed Emergency Plan, the requirement for the on shift RP Technician is maintained as well as the 60 minute augmentation time at the Alert or higher classification for the offsite survey teams. The OSRPF Coordinator is also maintained as a 60 minute responder and would report to the Rad/Chem Coordinator in the TSC.
The proposed Emergency Plan would extend the Rad/Chem Coordinator position response from 30 minutes to 60 minutes. The proposed revision does not impact the timing of the offsite survey major task which would be maintained at 60 minutes.
Table 5.1 on page 17 of 24 in Enclosure 1 to Attachment 1 of the original application provides:
one (1) person assigned to Field Monitoring Team 1 and one (1) person assigned to Field Monitoring Team 2 augmenting at 60 minutes.
DRAFT
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided for the major function of Offsite Surveys/On-site (Exclusion Area Surveys):
At variance (temporary). Table B-1 requires 3-30 min and 3-60 min. Nuclear Plant Specialist (Chem) and RadChem Techs will not be fully qualified until 12/31/82, at which time, 3 & 3 will be met.
Please explain how the proposed ERO maintains the commitment for offsite surveys as described in the February 18, 1982 letter cited above. Additionally, clarify how having one (1) 60 minute responder for each Field Monitoring Team meets the intent of EPIP 7.3.1, Offsite Radiological Sampling and Surveys, as it states in step 5.1.1:
Each Field Monitoring Shall have a minimum of two persons.
RAI-PBNP-6:
Page 8 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for Onsite (out of plant), In-Plant Surveys Major Task:
The current revision maintains the requirement for one RP Technician assigned to complete in-plant and on-site surveys. The site, per procedure, requires the use of electronic personal dosimetry (EPD) which are manually set to established emergency dose and dose rate alarms as well as radiation work permits which establish the necessary preset warnings/alarms associated with the EPD. The current Emergency Plan provides for additional support of onsite and in-plant surveys through augmentation of the RP Leader position in the OSC [Operations Support Center]. The RP Leader is a 60 minute responder positon.
The proposed change maintains the requirement for one RP Technician on-shift and augmentation of the RP Leader as a 60 minute responder position. The proposed change does not impact the timing of the Onsite or In-plant survey Major Task.
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided for two (2) 30-minute responders and two (2) 60-minute responders with the following comment for the major function of Offsite Surveys/On-site (Exclusion Area Surveys:
At variance (temporary). Table B-1 requires 3-30 min and 3-60 min. Nuclear Plant Specialist (Chem) and RadChem Techs will not be fully qualified until 12/31/82, at which time, 3 & 3 will be met.
Please explain how the proposed ERO maintains the commitment for onsite (out of plant), in-plant surveys as described in the February 18, 1982 letter cited above. Additionally, clarify how having one (1) person (RP Leader) reporting to the OSC provides additional support for onsite and in-plant surveys. What are the training and qualification requirements for the RP Leader position as compared to an RP Technician?
DRAFT
RAI-PBNP-7:
Page 11 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for Technical Support Major Task:
The current Emergency Plan includes an Engineering Coordinator position in the TSC with a response time of 60 minutes from an Alert or higher classification.
The proposed change maintains the Engineering Coordinator position and response time in the TSC. The proposed change does not impact the Technical Support major task.
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided for the major function of Technical Support:
Core Thermal/Hydraulics 1 [30 minutes],
Electrical 1 [60 minutes], and Mechanical 1 [60 minutes].
Please explain how the proposed ERO maintains the commitment for technical support as described in the February 18, 1982 letter cited above. Additionally, clarify how the Engineering Coordinator position meets the intent of Table B-1 to NUREG-0654 for the major task of Technical Support.
RAI-PBNP-8:
Page 11 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for Repair and Corrective Actions Major Task:
The current Emergency Plan maintains the requirement for augmentation of an I&C
[Instrument and Control] Supervisor and has revised the Maintenance Supervisor position to specify that either a Mechanical Maintenance or Electrical Maintenance Leader is required in the OSC. The current Emergency Plan maintains the requirement for response of the I&C and Mechanical/Electrical Leader positions within 30 minutes of an Alert or higher classification.
The proposed change would extend the response time for the I&C and Mechanical/Electrical Leader positions from 30 minutes to 60 minutes from the time of and Alert or higher classification.
DRAFT
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided the following commitment for the major function of Repair and Corrective Actions:
[Mechanical Maintenance] 1 [60 minutes],
[Electrical Maintenance] 1 [30 minutes] 1 [60 minutes], and
[I&C] 1 [30 minutes].
Please explain how the proposed ERO maintains the commitment for repair and corrective actions as described in the February 18, 1982 letter cited above. Additionally, clarify how the I&C and Mechanical/Electrical Leader positions meet the intent of NUREG-0654 major task of repair and corrective actions?
RAI-PBNP-9:
Pages 11 and 12 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for Protective Actions (In-Plant) Major Task:
The current Emergency Plan requires activation of the RP Leader position reporting to the OSC within 60 minutes of an Alert or higher classification.
The proposed change maintains the requirement for 60 minute response to the OSC by the RP Leader at an Alert or higher classification.
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided the following commitment for the major function of Protective Actions (In-Plant):
Rad Protection 2 [30 minutes] 2 [60 minutes].
Please explain how the proposed ERO maintains the commitment for protective actions (in-plant) as described in the February 18, 1982 letter. Additionally, clarify how having one (1)
Radiation Protection trained person (RP Leader) responding to the OSC in 60 minutes provides adequate protective actions (in-plant) under possibly changing radiological conditions for:
- Access control,
- HP coverage of search and rescue,
- HP coverage for firefighting,
- HP coverage for repair and corrective actions, and
- Issuance and setting of dosimetry.
DRAFT
RAI-PBNP-10: of the original application provides a comparison between NUREG-0654, the June 10, 1983 NRC-approved Emergency Plan Revision 20 (ADAMS Legacy Accession No. 8306130431), the current plan, and the proposed changes. It provides the following note:
- The PBNP Emergency Plan Revision 20 commitment stated If appropriate, the TSC will be activated in approximately 30 minutes and be fully operational within one hour.
The Plan did not specifically identify 30 minute and 60 minute responders.
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided 30 minute and 60 minute responders.
Please explain the discrepancy, or revise accordingly to address commitment.
RAI-PBNP-11: of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following note on Table 4, Radiation Protection &
Chemistry:
Note: AOs [auxiliary operators] are self-monitoring. AOs are trained as Advanced RAD
[radiation] workers and can provide personal job coverage without RP support Please provide a description of the Advanced Radiation Worker Program. This should include training plans, qualification cards and frequency of training, as applicable to demonstrate equivalency to a task qualified health physics technician consistent with the staff guidance provided in Health Physics Position (HPPOS) 238, Health Physics Position on Task Qualification of Health Physics Technicians.
RAI-PBNP-12:
Page 14 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for the Site Access Control and Personnel Accountability Function:
Per NUREG-0654 Revision 1, the Site Access Control and Personnel Accountability functional area is addressed by Security personnel in accordance with the Site Security Plan.
In Revision 20 of EP 6.0, dated November 9, 1983 site access control and accountability is identified as a function of the Security Supervisor on-shift and is detailed in the Site Security Plan.
The current Emergency Plan maintains this requirement through the Physical Security Plan.
The proposed changes to the Emergency Plan also maintain this requirement, therefore, the Site Access Control and Personnel Accountability functional area is not impacted by the proposed change.
DRAFT
However, on page 5 of 14 of the supplemental information it states, in part, Additionally, the Security Shift Supervisor on-shift who performs transmission of the offsite notification information will report to the TSC upon activation of the ERO and continue to perform this function in the TSC until it is transitioned to the State/County Communicator position in the EOF.
Section 4.1.1.e of EP 6.0, Emergency Measures provides the following:
The Security Shift Supervisor will verify complete accountability using the security computer or the manual accountability procedure, and will forward this information to the TSC Manager. If the TSC is not activated, this information will be forwarded to the Shift Manager.
Please clarify who is performing accountability and that it has been evaluated consistent with Commission Order EA-02-026.
THE END DRAFT
NRR-PMDAPEm Resource From: Chawla, Mahesh Sent: Tuesday, October 06, 2015 2:23 PM To: Cross, William (WILLIAM.CROSS@fpl.com); michael.millen@nexteraenergy.com; Mrozinsky, Richard (Richard.Mrozinsky@nexteraenergy.com)
Cc: Pelton, David; Anderson, Joseph; Norris, Michael; Wasem, Michael
Subject:
Request for Additional Information - Point Beach LAR 277 - Revision to Staff Augmentation Times in the Point Beach Nuclear Plant Emergency Plan Attachments: Point Beach ERO Staffing LAR - Draft RAIs_10-05-15.docx By letter dated June 12, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15166A042), and supplemented by letters dated August 11, and August 28, 2015, (ADAMS) Accession Numbers ML15223B277 and ML15240A017, respectively), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted a license amendment for Point Beach Nuclear Plant (PBNP), Units 1 and 2. The proposed amendment would revise the PNBP Emergency Plan, to increase the staff augmentation times for Emergency Response Organization (ERO) response functions.
The NRC staff has reviewed the information provided in your application and subsequent supplements. In order to complete our review, please provide your response to the attached request for additional information. Please arrange a teleconference with the NRC staff to discuss the requested information at your earliest possible. Thanks Mahesh Chawla Project Manager Phone: 301-415-8371 Fax: 301-415-1222 mahesh.chawla@nrc.gov 1
Hearing Identifier: NRR_PMDA Email Number: 2446 Mail Envelope Properties (Mahesh.Chawla@nrc.gov20151006142300)
Subject:
Request for Additional Information - Point Beach LAR 277 - Revision to Staff Augmentation Times in the Point Beach Nuclear Plant Emergency Plan Sent Date: 10/6/2015 2:23:13 PM Received Date: 10/6/2015 2:23:00 PM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:
"Pelton, David" <David.Pelton@nrc.gov>
Tracking Status: None "Anderson, Joseph" <Joseph.Anderson@nrc.gov>
Tracking Status: None "Norris, Michael" <Michael.Norris@nrc.gov>
Tracking Status: None "Wasem, Michael" <Michael.Wasem@nrc.gov>
Tracking Status: None "Cross, William (WILLIAM.CROSS@fpl.com)" <WILLIAM.CROSS@fpl.com>
Tracking Status: None "michael.millen@nexteraenergy.com" <michael.millen@nexteraenergy.com>
Tracking Status: None "Mrozinsky, Richard (Richard.Mrozinsky@nexteraenergy.com)"
<Richard.Mrozinsky@nexteraenergy.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 1012 10/6/2015 2:23:00 PM Point Beach ERO Staffing LAR - Draft RAIs_10-05-15.docx 46451 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY PLAN CHANGE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301 By letter dated June 12, 2015, and supplemented by letters dated August 11 and August 28, 2015, (Agencywide Documents Access and Management System (ADAMS) Accession Numbers ML15166A042, ML15223B277 and ML15240A017, respectively), NextEra Energy Point Beach, LLC (NextEra) is requesting an amendment to Renewed Facility Operating Licenses DPR-24 and DPR-27 for the Point Beach Nuclear Plant (PBNP) Units 1 and 2, respectively. NextEra proposes to revise the Point Beach Emergency Plan, to increase the staff augmentation times for Emergency Response Organization (ERO) response functions.
Additional changes include relocation of the Emergency Director and Emergency Action Level Monitor positions, and the addition of an Assistant Emergency Operations Facility Manager position.
The staff reviewed the referenced NRC safety evaluation report (SER) dated June 10, 1983 (ADAMS Legacy Accession No. 8306130431), as part of its evaluation of the proposed changes. As referenced in the SER, the staff also reviewed letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), with a specific focus on Attachment 2 that provided a comparison of the PBNP on-shift staffing and augmentation to Table B-1 (Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies) of Revision 1 to NUREG-0654/FEMA-REP-1 (NUREG-0654), Criteria for Preparation and Evaluation of Radiological Emergency response Plans and Preparedness in Support of Nuclear Power Plants.
The staff identified two additional approvals for Technical Specification changes to Operations staffing, License Amendments No. 91 and 95, dated April 8, 1985 (ADAMS Accession No. ML021930508), and License Amendments No. 190 and 195, dated August 11, 1999 (ADAMS Accession No. ML021980126). These are the only additional NRC approvals since the original SER.
Additionally, by letter dated January 25, 1991 (ADAMS Legacy Accession No. 9101290140),
Wisconsin Electric Power Company informed the NRC that the Duty and Call Superintendents would no longer reside within the 15 miles of the site as discussed in the February 18, 1982 letter. The NRC acknowledge this in letter dated March 21, 1991 (ADAMS Legacy Accession No. 9104020370).
The requests for additional information (RAIs) listed below, are needed to support NRC staffs continued technical review of the proposed Emergency Plan change.
DRAFT
RAI-PBNP-1:
Page 4 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides that the current Emergency Plan identifies the Emergency Director (EOF) as being responsible for State, local and Federal notification. It further provides that the new position of the Emergency Director in the Technical Support Center (TSC) will be assigned the notification function. Section 40.1.1 on page 23 of 30 of Appendix A to the original application provides that the Emergency Director is only responsible for NRC (ENS)
Communications. Please explain this discrepancy, or revise as appropriate to address conflicting statements.
RAI-PBNP-2:
Page 4 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following:
The proposed change includes transmission of the notification information to the State and County by the Security Shift Supervisor position. This position is maintained as an on-shift security department resource dedicated to this function. Upon ERO activation, the Security Shift Supervisor would report to the TSC and perform this function until it is transitioned to the EOF within 90 minutes from event classification. This change allows the notification function to transition from the Control Room to the TSC in the same timeframe (60 minutes) as the function transitions from the Control Room to the EOF under the current Emergency Plan and so maintains the capability for the major task of state/local notification.
Table 5.1 of the proposed and current plan provides that the function of State and local communication is performed on-shift by the Security Shift Supervisor.
EPIP 1.1, Course of Actions, states in step 5.2:
Direct the Security Shift Supervisor to report to the Control Room.
Please explain the process for transition of notifications from the Control Room to the TSC at 60 minutes.
RAI-PBNP-3:
Section 3.1.10 of EP 5.0, Organization Control of Emergencies, provides the following:
A Security Shift Supervisor (SSS) is available to perform state and local notifications.
During emergency situations, the SSS reports to the Security Coordinator in the TSC.
Has this collateral duty been evaluated against Commission Order EA-02-026? Additionally, is there Emergency Plan guidance to identify an alternate individual to serve as a communicator if the SSS is not available during a hostile action-based event?
DRAFT
RAI-PBNP-4:
Page 7 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following:
In the current Emergency Plan, dose assessment is completed by the on-shift Operations Senior Reactor Operator (SRO) in the unaffected Unit and the task is transitioned to Dose/PAR Coordinator in the EOF while additional support for this major task is provided by the Rad/Chem Coordinator in the TSC.
In the proposed Plan, the Rad/Chem Coordinator response would be extended from 30 minutes to a 60 minute responder and the Dose/PAR Coordinator response would be extended from 30 to 90 minutes. The augmentation change for the Rad/Chem Coordinator position in the TSC would result in the performance of the dose assessment task on-shift for an additional 30 minutes. The completion of on-shift dose assessment activities was evaluated during the On-Shift Staffing Analysis. The analysis showed that an onshift SRO was available to complete dose assessment in the scenarios that included a radiological release for up to 60 minutes.
Please provide evidence, that during an event affecting both units, one of the on-shift SROs would be able to perform the offsite dose assessment function for an additional 30 minutes as described in the proposed Plan.
RAI-PBNP-5:
Page 8 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for the Offsite Surveys Major Task:
The current Emergency Plan maintains the one on-shift RP Technician as well as the 60 minute augmentation time at the Alert or higher classification for the offsite survey teams. The Dose/PAR Coordinator position, a 30 minute responder in the EOF is responsible for providing field monitoring team oversight in conjunction with the Offsite Radiation Protection Facility (OSRPF) Coordinator, a 60 minute responder in the OSRPF.
In the proposed Emergency Plan, the requirement for the on shift RP Technician is maintained as well as the 60 minute augmentation time at the Alert or higher classification for the offsite survey teams. The OSRPF Coordinator is also maintained as a 60 minute responder and would report to the Rad/Chem Coordinator in the TSC.
The proposed Emergency Plan would extend the Rad/Chem Coordinator position response from 30 minutes to 60 minutes. The proposed revision does not impact the timing of the offsite survey major task which would be maintained at 60 minutes.
Table 5.1 on page 17 of 24 in Enclosure 1 to Attachment 1 of the original application provides:
one (1) person assigned to Field Monitoring Team 1 and one (1) person assigned to Field Monitoring Team 2 augmenting at 60 minutes.
DRAFT
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided for the major function of Offsite Surveys/On-site (Exclusion Area Surveys):
At variance (temporary). Table B-1 requires 3-30 min and 3-60 min. Nuclear Plant Specialist (Chem) and RadChem Techs will not be fully qualified until 12/31/82, at which time, 3 & 3 will be met.
Please explain how the proposed ERO maintains the commitment for offsite surveys as described in the February 18, 1982 letter cited above. Additionally, clarify how having one (1) 60 minute responder for each Field Monitoring Team meets the intent of EPIP 7.3.1, Offsite Radiological Sampling and Surveys, as it states in step 5.1.1:
Each Field Monitoring Shall have a minimum of two persons.
RAI-PBNP-6:
Page 8 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for Onsite (out of plant), In-Plant Surveys Major Task:
The current revision maintains the requirement for one RP Technician assigned to complete in-plant and on-site surveys. The site, per procedure, requires the use of electronic personal dosimetry (EPD) which are manually set to established emergency dose and dose rate alarms as well as radiation work permits which establish the necessary preset warnings/alarms associated with the EPD. The current Emergency Plan provides for additional support of onsite and in-plant surveys through augmentation of the RP Leader position in the OSC [Operations Support Center]. The RP Leader is a 60 minute responder positon.
The proposed change maintains the requirement for one RP Technician on-shift and augmentation of the RP Leader as a 60 minute responder position. The proposed change does not impact the timing of the Onsite or In-plant survey Major Task.
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided for two (2) 30-minute responders and two (2) 60-minute responders with the following comment for the major function of Offsite Surveys/On-site (Exclusion Area Surveys:
At variance (temporary). Table B-1 requires 3-30 min and 3-60 min. Nuclear Plant Specialist (Chem) and RadChem Techs will not be fully qualified until 12/31/82, at which time, 3 & 3 will be met.
Please explain how the proposed ERO maintains the commitment for onsite (out of plant), in-plant surveys as described in the February 18, 1982 letter cited above. Additionally, clarify how having one (1) person (RP Leader) reporting to the OSC provides additional support for onsite and in-plant surveys. What are the training and qualification requirements for the RP Leader position as compared to an RP Technician?
DRAFT
RAI-PBNP-7:
Page 11 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for Technical Support Major Task:
The current Emergency Plan includes an Engineering Coordinator position in the TSC with a response time of 60 minutes from an Alert or higher classification.
The proposed change maintains the Engineering Coordinator position and response time in the TSC. The proposed change does not impact the Technical Support major task.
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided for the major function of Technical Support:
Core Thermal/Hydraulics 1 [30 minutes],
Electrical 1 [60 minutes], and Mechanical 1 [60 minutes].
Please explain how the proposed ERO maintains the commitment for technical support as described in the February 18, 1982 letter cited above. Additionally, clarify how the Engineering Coordinator position meets the intent of Table B-1 to NUREG-0654 for the major task of Technical Support.
RAI-PBNP-8:
Page 11 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for Repair and Corrective Actions Major Task:
The current Emergency Plan maintains the requirement for augmentation of an I&C
[Instrument and Control] Supervisor and has revised the Maintenance Supervisor position to specify that either a Mechanical Maintenance or Electrical Maintenance Leader is required in the OSC. The current Emergency Plan maintains the requirement for response of the I&C and Mechanical/Electrical Leader positions within 30 minutes of an Alert or higher classification.
The proposed change would extend the response time for the I&C and Mechanical/Electrical Leader positions from 30 minutes to 60 minutes from the time of and Alert or higher classification.
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Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided the following commitment for the major function of Repair and Corrective Actions:
[Mechanical Maintenance] 1 [60 minutes],
[Electrical Maintenance] 1 [30 minutes] 1 [60 minutes], and
[I&C] 1 [30 minutes].
Please explain how the proposed ERO maintains the commitment for repair and corrective actions as described in the February 18, 1982 letter cited above. Additionally, clarify how the I&C and Mechanical/Electrical Leader positions meet the intent of NUREG-0654 major task of repair and corrective actions?
RAI-PBNP-9:
Pages 11 and 12 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for Protective Actions (In-Plant) Major Task:
The current Emergency Plan requires activation of the RP Leader position reporting to the OSC within 60 minutes of an Alert or higher classification.
The proposed change maintains the requirement for 60 minute response to the OSC by the RP Leader at an Alert or higher classification.
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided the following commitment for the major function of Protective Actions (In-Plant):
Rad Protection 2 [30 minutes] 2 [60 minutes].
Please explain how the proposed ERO maintains the commitment for protective actions (in-plant) as described in the February 18, 1982 letter. Additionally, clarify how having one (1)
Radiation Protection trained person (RP Leader) responding to the OSC in 60 minutes provides adequate protective actions (in-plant) under possibly changing radiological conditions for:
- Access control,
- HP coverage of search and rescue,
- HP coverage for firefighting,
- HP coverage for repair and corrective actions, and
- Issuance and setting of dosimetry.
DRAFT
RAI-PBNP-10: of the original application provides a comparison between NUREG-0654, the June 10, 1983 NRC-approved Emergency Plan Revision 20 (ADAMS Legacy Accession No. 8306130431), the current plan, and the proposed changes. It provides the following note:
- The PBNP Emergency Plan Revision 20 commitment stated If appropriate, the TSC will be activated in approximately 30 minutes and be fully operational within one hour.
The Plan did not specifically identify 30 minute and 60 minute responders.
Letter dated February 18, 1982 (ADAMS Legacy Accession No. 8203030116), specifically , Comparison of PBNP Augmentation to Table B-1 of NUREG-0654, provided 30 minute and 60 minute responders.
Please explain the discrepancy, or revise accordingly to address commitment.
RAI-PBNP-11: of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following note on Table 4, Radiation Protection &
Chemistry:
Note: AOs [auxiliary operators] are self-monitoring. AOs are trained as Advanced RAD
[radiation] workers and can provide personal job coverage without RP support Please provide a description of the Advanced Radiation Worker Program. This should include training plans, qualification cards and frequency of training, as applicable to demonstrate equivalency to a task qualified health physics technician consistent with the staff guidance provided in Health Physics Position (HPPOS) 238, Health Physics Position on Task Qualification of Health Physics Technicians.
RAI-PBNP-12:
Page 14 of 14 of the supplemental information (letter dated August 28, 2015 (ADAMS Accession Number ML15240A017) provides the following for the Site Access Control and Personnel Accountability Function:
Per NUREG-0654 Revision 1, the Site Access Control and Personnel Accountability functional area is addressed by Security personnel in accordance with the Site Security Plan.
In Revision 20 of EP 6.0, dated November 9, 1983 site access control and accountability is identified as a function of the Security Supervisor on-shift and is detailed in the Site Security Plan.
The current Emergency Plan maintains this requirement through the Physical Security Plan.
The proposed changes to the Emergency Plan also maintain this requirement, therefore, the Site Access Control and Personnel Accountability functional area is not impacted by the proposed change.
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However, on page 5 of 14 of the supplemental information it states, in part, Additionally, the Security Shift Supervisor on-shift who performs transmission of the offsite notification information will report to the TSC upon activation of the ERO and continue to perform this function in the TSC until it is transitioned to the State/County Communicator position in the EOF.
Section 4.1.1.e of EP 6.0, Emergency Measures provides the following:
The Security Shift Supervisor will verify complete accountability using the security computer or the manual accountability procedure, and will forward this information to the TSC Manager. If the TSC is not activated, this information will be forwarded to the Shift Manager.
Please clarify who is performing accountability and that it has been evaluated consistent with Commission Order EA-02-026.
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