ML17276B489
| ML17276B489 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/23/2017 |
| From: | Balwant Singal Plant Licensing Branch IV |
| To: | |
| Singal B, NRR/DORL/LPL4-1 | |
| References | |
| CAC MG0174, EPID L-2017-LRM-0017 | |
| Download: ML17276B489 (20) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 23, 2017 LICENSEE: Wolf Creek Nuclear Operating Corporation FACILITY: Wolf Creek Generating Station
SUBJECT:
SUMMARY
OF SEPTEMBER 25, 2017, PUBLIC MEETING WITH WOLF CREEK NUCLEAR OPERATING CORPORATION REGARDING THE PROPOSED LICENSE AMENDMENT REQUEST FOR CHANGES IN EMERGENCY PLAN STAFF AUGMENTATION RESPONSE TIMES FOR WOLF CREEK GENERATING STATION (CAC NO. MG0174; EPID L-2017-LRM-0017)
On September 25, 2017, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Wolf Creek Nuclear Operating Corporation (WCNOC, the licensee) and its contractors via teleconference. The purpose of the meeting was to discuss the proposed license amendment request (LAR) to the Wolf Creek Generating Station (WCGS) Emergency Plan for changes in Emergency Response Organization (ERO) staffing and augmentation response times. The meeting notice and agenda are located in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML17268A052. 1 A list of attendees is provided as Enclosure 1.
The licensee explained the emergency planning (EP) licensing basis, the proposed changes to the WCGS Emergency Plan and the justification for the proposed changes, applicable regulatory guidance, and the proposed LAR format and schedule. A copy of the licensee's presentation slides is provided as Enclosure 2. The NRC staff requested the licensee to address the following technical issues in the proposed LAR:
- Documentation that the proposed standardized response time of 90 minutes for the WCGS Technical Support Center (TSC), Operations Support Center (OSC), and Emergency Operating Facility (EOF) is consistent with the response times assumed by State/local support organizations for the activation of their respective emergency operations centers.
- An evaluation demonstrating that there would be no additional reliance, nor any undue burden on the main control room (MCR) operators as a result of consolidation of some of the positions in the MCR, TSC, OSC, or EOF, especially during an extended event.
1 Meeting date was changed from September 14, 2017, to September 25, 2017.
The NRC staff also asked the following additional questions during the presentation:
- Was the original approval of the WCGS Emergency Plan with a full-time licensed practitioner in addition to the first aid responders? The licensee confirmed that original approval was based on a full-time licensed practitioner and first aid responders. The proposed change will elimintate the reference to the licensed practitioner in the emergency plan.
- In response to the question about what other methods of dose assessment are available, the licensee stated that the current method referenced in the WCGS Emergency Plan to perform dose assessment using containment pressure indication overestimates the dose. The licensee has several other more accurate dose assessment methods for dose assessment available and the method proposed to be used will be described in the LAR.
- In response to the NRC staff question, the licensee confirmed that time Zero (T=O) is the time of event classification and end time will be the respective facility activation. There is no change to these definitions, which will remain the same as in the current WCGS Emergency Plan.
NRC staff also described that ERO augmented staffing needs to address a broad range of accident events, and is not limited to the scenarios listed in Nuclear Energy Institute (NEI) 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities" (ADAMS Accession No. ML111751698). In addition, the NRC staff emphasized that minimum staffing (per Table 8-1 of NUREG-0654 2) must be sufficient to support initial facility activation without immediate augmentation, and this should be reflected in emergency plan implementing instructions.
Jessica Snook of the Radiation Control Program, Kansas Department of Health and Environment provided transcribed comments on behalf of the State of Kansas State Official. provides the copy of the transcript read by the State Official during the meeting and provided by e-mail after the meeting. The NRC staff suggested that the licensee may want to consider tabletops or drills to validate that proposed ERO staffing and augmentation time changes address State concerns as applicable.
No Public Meeting Feedback forms were received.
2 NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"
(ADAMS Accession No. ML113010596).
Please direct any inquiries to me at 301-415-3016 or via e-mail at Balwant.Singal@nrc.gov.
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Wwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482
Enclosures:
- 1. List of Attendees
- 2. Presentation Slides
- 3. State of Kansas Comments cc w/encl: Distribution via Listserv
LIST OF ATTENDEES SEPTEMBER 25, 2017. TELECONFERENCE WITH WOLF CREEK NUCLEAR OPERATING CORPORATION PROPOSED CHANGES TO THE EMERGENCY PLAN FOR WOLF CREEK GENERATING STATION U.S. Nuclear Regulatory Commission Joseph D. Anderson, Office of Nuclear Security and Incident Response (NSIR)
Michael Norris, NSIR Thomas J. Wengert, Office of Nuclear Reactor Regulation (NRR)
Balwant K. Singal, NRR Licensee Attendees Tim East, Wolf Creek Nuclear Operating Corporation (WCNOC)
Cindy Hafenstine, WCNOC Bill Muilenburg, WCNOC Lu Stone, WCNOC Nicole Good, WCNOC Bob Kidwell, Enercon State of Kansas Representatives Jessica Snook, Kansas Department of Health and Environment Jonathan York, Kansas Division of Emergency Management Members of the Public None Enclosure 1
ENCLOSURE 2 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION LICENSE AMENDMENT REQUEST FOR CHANGE IN EMERGENCY PLAN STAFF AUGMENTATION RESPONSE TIMES PRESENTATION SLIDES
WCNOC -NRC Pre-submittal Meeting License Amendment Request for Change in Emergency Plan Staff Augmentation Response Times September 14, 2017 Wolf Creek Nuclear Operating Company Wolf Creek ... a member of the STAR s Alliance
NRC WC NOC
- Timothy East, Superintendent Emergency Planning
- Cindy Hafenstine, Manger Nuclear Regulatory Affairs
- Bill Muilenburg, Supervisor Licensing
- Lu Stone, Licensing
- Nicole Good, Licensing ENERCON
- Lori Tkaczyk, Senior Technical Specialist
- Bob Kidwell, Project Manager/Senior Technical Specialist
- Pre-Submittal Meeting Purpose
- Emergency Plan Licensing Basis
- Proposed Emergency Plan Changes
- Reason for Proposed Changes
- LAR Format
- Regulatory Guidance
- LAR Schedule
- Conclusions
- Questions?
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- Last NRC Approved Plan - Revision 15, approved January 1985 (Wolf Creek Generating Station)
- Current Emergency Plan is procedure AP 06-002, Revision 18A (Wolf Creek Nuclear Operating Company)
- The LAR includes an analysis of NUREG-0654 Table B-1 functions as implemented in the Emergency Plan between the last approved and current revisions.
- Standardize Technical Support Center, Operations Support Center and Emergency Operating Facility at 90 minute response time.
- Replace the current full time licensed practitioner position with the on-shift 24/7 first aid responders.
- Reduce the number of required Emergency Response Organization positions through consolidation and elimination.
- Remove reference to performing dose assessment using containment pressure indication.
- Significant increases in the number of on-shift positions have occurred over the past several years. Currently - 17 positions; 1985 -10 positions.
- Licensed practitioner only available during business hours. First Aid responders on-shift available 24/7.
- Expanding augmentation times for the TSC/OSC and reducing the number of ERO positions will increase the number of eligible plant personnel available to fill critical ERO positions and add valuable expertise.
- More accurate methods for dose assessment exist.
- Enclosures/Attachments include:
- Technical Justification based on improvements in plant systems, procedures, dose assessment and training
- Functional analysis of Table B-1 Major Tasks
- Summary table of Emergency Plan changes
- Marked up copy of the Emergency Plan
- Clean copy of the Emergency Plan
- ERO Task Analysis
- Table B-1 Comparative Chart
- Letters of Offsite Response Organization Concurrence
- Commitments
- RG 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors"
- NUREG-0654/FEMA-REP- l, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants"
- NSIR/DPR-ISG-01, "Interim Staff Guidance Emergency Planning for Nuclear Power Plants"
- RIS 2016-10, "License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation"
- NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities"
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- Proposed staffing continues to minimize impact of radiological emergencies and provide protection of public health and safety
- Supported by Technical Justification and Functional Analysis
- Revised Emergency Plan continues to meet
§50.54(q) (2), §50 Appendix E, and the planning standards of §50.47(b)
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ENCLOSURE 3 STATE OF KANSAS COMMENTS
Transcript of Comments Made by State of Kansas Representative Jessica Snook, Kansas Department of Health and Environment (Script Provided by the State Representative)
My name is Jessi Snook. I am an Environmental Program Supervisor with the Radiation Control Program at the Kansas Department of Health and Environment. KDHE would like to express our concern with Wolf Creek's proposed changes to reduce the number of required Emergency Response Organization positions through consolidation and elimination. We understand the need for reduction at this time, however, we believe the changes in the personnel that are being proposed will have a direct impact on KDHE's mission to protect the health and safety of the public and emergency workers in Kansas. The changes that will affect KDHE by impacting the timeliness of making protective actions include reducing the number of Wolf Creek dose assessment staff, eliminating the Facility Technician, reducing the number of field team communicators, and reducing the number of field team positions.
Wolf Creek's plan to give responsibilities of the dose assessment and facility tech positions to the position of the EOF Radiological Coordinator will add an extra burden to that position and take away from the support that position provides to KDHE. KDHE works closely with the person in this role to gain awareness of plant status, radiological conditions, discuss recommendations for protective actions, ensure data is consistent and communicated in a timely manner, discuss field team mission tasks, and ensure situational awareness for both Wolf Creek and KDHE. Redirecting attention to facility issues, sample receipt, and dose assessment will reduce the time available to fulfill the essential roles of this position which support KDHE and minimize their availability for consultation with the State Radiological Assessment Manager.
Reducing the number of field team communicators from two to one will impact the ability to direct and track field teams, receive field data, and communicate changes in plant status, protective actions, and meteorological conditions in a timely manner. Communication plays an integral part in any drill, exercise, or real world emergency. We recommend alternate solutions that minimize the reassignment of technical duties to positions at the Coordinator level.
Reducing the number of field team positions from four to three has the potential to reduce effectiveness and interfere with the mission of the teams to monitor and characterize a plume.
Teams are challenged with wind speeds, shifts, and geographic or manmade barriers. To safely identify the boundaries of a plume and collect air samples in a timely manner, a minimum of four teams should be deployed. Rapid assessments by plume monitoring and characterization is a vital mission of KDHE and a requirement of the FEMA REP Program Manual. We believe it will be compromised by the loss of one of the four radiological monitoring teams. We do not support eliminating one of the field teams without an alternate method to obtain the data needed to characterize and track a radioactive plume. At this time, KDHE is researching alternative methods for plume monitoring using new technologies and/or deployable fixed monitors.
We respectfully request consideration to be given to these concerns that we believe could lead to a reduction in effectiveness of the offsite response.
SUBJECT:
SUMMARY
OF SEPTEMBER 25, 2017, PUBLIC MEETING WITH WOLF CREEK NUCLEAR OPERATING CORPORATION REGARDING THE PROPOSED LICENSE AMENDMENT REQUEST FOR CHANGES IN EMERGENCY PLAN STAFF AUGMENTATION RESPONSE TIMES FOR WOLF CREEK GENERATING STATION (CAC NO. MG0174; EPID L-2017-LRM-0017)
DATED OCTOBER 23, 2017 DISTRIBUTION:
PUBLIC RidsRgn4MailCenter Resource LPL4 Reading File JAnderson, NSIR RidsACRS_MailCTR Resource MNorris, NSIR RidsNrrDorl Resource TWengert, NRR RidsNrrDorlLpl4 Resource TWertz, NRR RidsNrrLAPBlechman Resource JBowen, EDO RIV RidsNrrPMWolfCreek Resource ADAMS A ccess1on Nos.: M eetmg
. Not1ce .
. ML17268A052 S ummary ML172768489 *via
. e-ma1*1 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DORL/LPL4 NAME BSingal PBlechman TWengert DATE 10/10/2017 10/10/2017 10/12/2017 OFFICE NSIR/DPR/RLB* NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JAnderson RPascarelli BSingal DATE 10/10/2017 10/23/2017 10/23/2017 OFFICIAL RECORD COPY