ML17290A353

Comment (1) of David Young on Behalf of Nuclear Energy Institute on Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1, Section Ii.B

ML17290A353
Person / Time
Site:	Nuclear Energy Institute
Issue date:	10/10/2017
From:	Young D Nuclear Energy Institute
To:	Dante Johnson Office of Nuclear Security and Incident Response
References
82FR42711 00001, NRC-2017-0190, NUREG-0654/FEMA-REP-1
Download: ML17290A353 (3)

Text

Page 1 of 1 Joil As of: 10/12/17 9:48 AM 1fil6 OCT I 2 /{H 9: 56 Received: October 10, 2017 Status: Pending_Post PUBLIC SUBMISSION Tracking No. lkl-8z55-ld3q Comments Due: October 11, 2017 RE(~[!V(() Submission Type: Web Docket: NRC-2017-0190 Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1,Section II.B Comment On: NRC-2017-0190-0001 Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1,Section II.B; Request for Comment Document: NRC-2017-0190-DRAFT-0001 Comment on FR Doc # 2017-19093 Submitter Information Name: David Young Submitter's Representative: Lana Dargan r/;1/cN17 Organization: Nuclear Energy Institute f"c2?~!hf 7/)

General Comment See Attached Attachments 10-10-17_Industry Comments on draft Technical Basis for the Proposed Guidance in NUREG-0654 FEMA-REP-1 Section II.B (2)

SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= ;J?h(_ ~(~~-s.5) https://www.fdms.gov/fdms/getcontent?objectld=0900006482bb5d6c&format=xml&showorig=false 10/12/2017

DAVID L. YOUNG Technical Advisor, Nuclear Security and Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004

~I NUCLEAR ENERGY INSTITUTE P: 202.739.8127 dly@nei.org nei.org October 10, 2017 Don Johnson Office of Nuclear Security and Incident Response, U.S. Nuclear Regulatory Commission, Washington; DC 20555-0001 Submitted via Regulations.gov Project Number: 689

Subject:

Industry comments on draft "Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1, Section H.B." [Regulations.gov Docket ID NRC-2017-0190J

Dear Mr. Johnson:

The Nuclear Energy Institute (NEI) and the industry are pleased to provide the following comments on the draft Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1,Section II.B.

• Section 2.4.2, Communications - The bases discusses an additional communicator position staffed at a Site Area Emergency (SAE) Emergency Classification Level (ECL). Please provide additional information regarding the purpose of this position. The Bases document states "For an SAE ECL, or greater, at least 1 additional communicator should be staffed in the EOF." The purpose of this additional communicator is not clear. Specifically, is the intent for this position to be an NRC communicator, or is this position expected to be qualified to perform State/local communications as well. Considering the NUREG-0654, Rev. 1, staffing guidance included an HPN Communicator, is the position expected to have sufficient background to perform HPN type communications. If the NRC ENS communicator is located in the EOF, is the expectation that this additional communicator be located in another facility (i.e., the TSC)? Additional detail regarding the purpose of this communicator would be helpful.

• Section 2.4.3, Radiation Protection -The bases document contains the following statement, "This function should be staffed by 2 qualified RP staff members on-shift (or 1 per unit for multi-unit sites). These staff members should not have any collateral duties during emergency response. "Many licensees currently utilize an on-shift RP tech to perform the on-shift Dose Assessment function. This assignment is a natural extension of RP Technician skills NUCLEAR. CLEAN AIR ENERGY

Mr. Don Johnson October 10, 2017 Page 2 and the practice has been found acceptable for many years. It would be helpful for the guidance to specifically allow for the assignment of the dose assessment function to an on-shift RP Technician as a collateral duty provided that the results of an on-shift staffing analysis, required by 10 CFR Part SO, Appendix E,Section IV.A.9, verify that all assigned functions can be satisfactorily performed.

• Section 2.4.10, Supervision of Repair Team Activities - The Bases document specifies maintenance craft "Supervisors" need to be staffed within 90 minutes. At some sites, there may be a limited number of available craft supervisors when divided between the mechanical, electrical and I&C maintenance disciplines. Many sites rely on "Lead" technicians who are qualified to direct troubleshooting and repair activities and experienced in leading maintenance teams in these types of tasks. Additional guidance would be helpful as to how these types of technicians can be integrated/ credited as an alternative approach to addressing the repair team supervisory function.

• Section 2.4.11, Field Monitoring Teams - The discussion of the Onsite Field Monitoring Team includes a driver position for the team. Considering the relatively small size of nuclear power plant sites, and that Owner Controlled Areas do not have extensive or congested road networks, it seems that a driver may not be necessary for the performance of the onsite field monitoring function at many sites (i.e., the monitor can drive his/herself between survey locations).

Additional guidance would be helpful as to how a licensee could provide site-specific conditions obviating the need for an onsite monitoring team driver.

If you have questions or require additional information, please do not hesitate to contact me at dly@nei.org or at my office number, 202.739.8127.

Sincerely,

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David Young