ML18022A352
| ML18022A352 | |
| Person / Time | |
|---|---|
| Issue date: | 06/12/2018 |
| From: | Robert Kahler Office of Nuclear Security and Incident Response |
| To: | Perkins-Grew S Nuclear Energy Institute |
| References | |
| Download: ML18022A352 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 12, 2018 Ms. Susan Perkins-Grew Senior Director, Emergency Preparedness and Risk Assessment Nuclear Energy Institute (NEI) 1201 F Street, NW, Suite 1100 Washington, DC 20004
SUBJECT:
ALTERNATIVE GUIDANCE FOR LICENSEE EMERGENCY RESPONSE ORGANIZATIONS
Dear Ms. Perkins-Grew:
NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (ADAMS Accession No. ML040420012) (NUREG-0654), provides generic guidance to nuclear power plant licensees and State and local governments to develop radiological emergency plans.
Section II.B, Table B-1 of NUREG-0654 provides guidance to licensees when developing emergency response organization (ERO) on-shift and augmented staffing levels. The Nuclear Regulatory Commission (NRC) and the Federal Emergency Management Agency (FEMA) are currently updating NUREG-0654. However, the guidance contained in Section II.B pertains strictly to nuclear power plant licensees and does not require FEMA review. A Technical Basis for this section can be found under ADAMS Accession Number ML16117A427. This Technical Basis was published for public comment at www.regulations.gov under Docket ID NRC-2017-0190, dated September 11, 2017. An extended public comment period for the revised guidance in Revision 2 of NUREG-0654/FEMA-REP-1, including Section II.B, was conducted from May 29, 2015 through October 13, 2015. Additionally,Section II.B and the supporting Technical Basis was the subject of a public meeting held on April 4th, 2017.
The NRC has revised Section II.B, Table B-1 of NUREG-0654, based in part on comments received from the public on the draft Revision 2 of NUREG-0654, located at www.regulations.gov under Docket ID FEMA-2012-0026. The revised ERO staffing guidance has been finalized, and the NRC will include it when the entire NUREG-0654, Revision 2, is ready for issuance. Until then, the NRC staff is making available on an interim basis the ERO on-shift and augmentation staffing plan (attached). Regardless of whether a licensee chooses to use the guidance contained in Revision 1 of NUREG-0654, the attached, or an alternative approach, licensees are still required to adhere to 10 CFR 50.54(q) when revising their ERO staffing plans.
Following issuance of Revision 2 of NUREG-0654, the NRC staff intends to revise Regulatory Guide (RG) 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," to document the acceptability of the revised guidance, which will also serve to supersede this
S. Perkins-McGrew letter. This letter is only intended to provide licensees with the attached guidance when voluntarily developing changes to licensee ERO staffing plans. Licensees use the attached at their own risk because it has not been formally approved for use through a RG. Any aspects of the NRCs ultimate revision to RG 1.101 that are not set forth in the attached would not constitute backfitting or a violation of issue finality.
The Office of Management and Budget has made the determination that NRC rule NRC-2017-0190, entitled Revision to NUREG-0654/FEMA-REP-1,Section II.B, Emergency Response Organization, is non-major under the Congressional Review Act.
Sincerely,
/RA/
Robert E. Kahler, Chief Policy and Oversight Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response
Attachment:
Table B Emergency Response Organization (ERO) Staffing and Augmentation Plan Technical
Contact:
Don A. Johnson, Senior EP Specialist (301)287-9230 don.johnson@nrc.gov
S. Perkins-McGrew
SUBJECT:
ALTERNATIVE GUIDANCE FOR LICENSEE EMERGENCY RESPONSE ORGANIZATIONS DISTRIBUTION:
NSIR/DPR Accession Number: ML18022A352 OFFICE NSIR/DPR/POB ADMIN/NSIR OGC:NLO NSIR/DPR/POB:BC NAME DJohnson CDiggs HBenowitz* RKahler DATE 1/17/2018 1/24/2018 2/8/2018 5/31/2018
- Via email.
OFFICIAL RECORD COPY
Attachment Table B-1: Emergency Response Organization (ERO) Staffing and Augmentation Plan NOTES
- i. The minimum number of personnel assigned vi. Many of these EP functions may be assigned as emergency preparedness (EP) functions for on- collateral duties; however, the licensee is shift and augmented response (henceforth called required to evaluate if the addition of collateral the ERO staffing plan) is dependent on specific duties would preclude the performance of EP licensee requirements and is as approved by the functions regardless of the other (non-EP)
NRC for the site-specific emergency plan. duties assigned to an individual responder.
Augmented response provides relief to the on-vii. The development of an ERO staffing plan shift staff of EP functions (if necessary) and (2) should use a performance-based approach to the provides support staff for effective emergency degree practicable. The licensee will need to plan implementation.
demonstrate that the listed EP functions are ii. This table lists the EP functions needed to constantly maintained. Once developed, and implement the typical emergency plan. It is approved by the NRC, changes to the minimum intended to provide a model for applicants and ERO staffing plan are evaluated and controlled licensees to consider in the development of in accordance with 10 CFR 50.54(q).
their site-specific emergency plan. The viii. The number of operations staff, security force minimum ERO staffing plan of a specific staff, or fire brigade staff on-shift is controlled licensee should be described.
by the site-specific Technical Specifications or iii. The minimum ERO staffing plan is that other licensing documents.
which is required to effectively implement the site- specific emergency plan (i.e., the emergency plan cannot be effectively implemented without this staff). The emergency plan should describe the minimum ERO staffing plan, while supporting implementing procedures can describe any other staff response desired by the licensee as long as this staff is not critical to effective emergency plan implementation The augmentation times listed are intended to provide a model for applicants and licensees to consider in the development of their site-specific emergency plan.
iv. The titles of the positions are as defined in the site-specific emergency plan.
- v. The locations of these positions are intended to provide a model for applicants and licensees to consider in the development of their site- specific emergency plan. Licensees may choose to have these positions, or functions, at other facilities and/or activated at different emergency classification levels (ECLs).
Emergency Operations Facility (EOF)/
Technical Support Center (TSC)/Operations Joint Information Support Center (OSC)
Center (JIC)/ Joint Information Emergency Preparedness System (JIS)
On-Shift (EP) Functions Site Area Alert or Greater Alert or Greater Emergency (SAE) or Greater Augment w/in 60 Augment w/in 90 min.1, 2 min.1, 2 Augment w/in 60 min.3 Command and Control
- Provide overall ERO command and control, until relieved.
- Approve emergency action level (EAL) and/ Operations Shift Emergency Emergency Not applicable or protective action Manager Coordinator (1) Director (1) recommendation (PAR) classifications, until relieved.
- Authorize personnel dose extensions, until relieved.
Communications Communicators (TSC)
As needed.
- Communicate EAL (2) and PAR classifications One communicator Communicator1 One communicator for Communicator (1) to offsite response staffed for NRC the NRC and one organizations (OROs), communications if communicator for including the NRC, needed.
OROs.
until relieved.
Radiation Protection
- Provide qualified radiation protection coverage for responders Additional Radiation accessing potentially Additional Radiation Protection Technicians unknown radiological Radiation Protection Technicians [In addition to environments during Protection [In addition to personnel on-shift and Not applicable emergency conditions. Personnel4 personnel on-shift] those responding within (OSC) (3) 60 min.]
- Provide in-plant surveys. (OSC) (3)
- Control dosimetry and radiologically controlled area access.
Emergency Operations Facility (EOF)/
Technical Support Center (TSC)/Operations Joint Information Support Center (OSC)
Center (JIC)/ Joint Information Emergency Preparedness System (JIS)
On-Shift (EP) Functions Site Area Alert or Greater Alert or Greater Emergency (SAE) or Greater Augment w/in 60 Augment w/in 90 min.1, 2 min.1, 2 Augment w/in 60 min.3 Supervision of Radiation Protection Staff and Site Radiation Protection
- Evaluate and assess plant and offsite radiological data in the development of onsite protective actions and offsite PARs, until relieved.
- Recommend onsite protective actions and offsite PARs to the Site Radiation Operations Shift Radiation Protection applicable decision- Protection Coordinator Not applicable Manager Manager (1) (EOF) maker, until relieved. (SRPC) (1) (TSC)
- Direct all radiation protection activities, including field monitoring team (FMT) direction, until relieved.
- Provide relevant information to applicable communicators who are communicating offsite PARs to OROs, until relieved.
Dose Assessments/
Projections
- Perform dose Dose Assessment/ Dose Assessment/
Dose Assessment/
assessments/projections Projection Staff (1) Not applicable Projection Staff (1)
Projection Staff 1 and provide input to (TSC) (EOF) applicable PAR decision-maker, until relieved.
Emergency Operations Facility (EOF)/
Technical Support Center (TSC)/Operations Joint Information Support Center (OSC)
Center (JIC)/ Joint Information Emergency Preparedness System (JIS)
On-Shift (EP) Functions Site Area Alert or Greater Alert or Greater Emergency (SAE) or Greater Augment w/in 60 Augment w/in 90 min.1, 2 min.1, 2 Augment w/in 60 min.3 Emergency Classification Advisor Emergency Classifications (1) (TSC)
- Evaluate plant Emergency Licensees should consider conditions and Classification having a liaison between Not applicable Not applicable recommend emergency Advisor1 Operations (Control Room) classifications, until and the TSC to perform this relieved. function.
TSC Engineering Staff
- (1) Electrical/
Instrumentation and Control (I&C):
Provide engineering coverage for the ERO Engineering related to electrical or Core/Thermal I&C equipment.
- Provide engineering Hydraulics coverage related to the Engineer1 * (1) Mechanical:
Provide As needed Not applicable specific discipline of the
- Evaluate reactor engineering assigned engineer, until conditions. coverage for the relieved. ERO related to mechanical equipment.
- (1) Core/Thermal Hydraulics: Evaluate reactor conditions.
Security Liaison (TSC) (1)
Security staffing per
- Coordinate security-Security the site-specific related activities and Not applicable Not applicable security plan. information with the Emergency Coordinator.
Emergency Operations Facility (EOF)/
Technical Support Center (TSC)/Operations Joint Information Support Center (OSC)
Center (JIC)/ Joint Information Emergency Preparedness System (JIS)
On-Shift (EP) Functions Site Area Alert or Greater Alert or Greater Emergency (SAE) or Greater Augment w/in 60 Augment w/in 90 min.1, 2 min.1, 2 Augment w/in 60 min.3 Maintenance Personnel (OSC)
Maintenance * (1) I&C Technician:
Personnel (OSC) Provide assistance (1 electrician, with logic 1 mechanic) manipulation,
- (1) Electrician: support for event Provide electrical mitigation and support for ECCS equipment repair, Not applicable Repair Team Activities equipment, event and support of Not applicable mitigation, and digital I&C if equipment repair. applicable.
Additional I&C staff
- (1) Mechanic: Provide may be called out if mechanical support needed.
for ECCS equipment, event mitigation, and
- Electricians -
equipment repair. As needed.
- Mechanics -
As needed.
Emergency Operations Facility (EOF)/
Technical Support Center (TSC)/Operations Joint Information Support Center (OSC)
Center (JIC)/ Joint Information Emergency Preparedness System (JIS)
On-Shift (EP) Functions Site Area Alert or Greater Alert or Greater Emergency (SAE) or Greater Augment w/in 60 Augment w/in 90 min.1, 2 min.1, 2 Augment w/in 60 min.3 OSC Supervisors
- (1) Electrical:
Supervise OSC activities related to electrical equipment.
- (1) Mechanical:
Supervise OSC Lead OSC activities related Supervisor (1) to mechanical equipment.
Supervision of Repair Not applicable
- Supervise OSC
- (1) I&C: Not applicable Team Activities activities as directed by Emergency Supervise Coordinator. OSC activities related to I&C equipment.
May be combined with Electrical Supervisor.
- (1) Radiation Protection:
Supervise OSC activities related to
Emergency Operations Facility (EOF)/
Technical Support Center (TSC)/Operations Joint Information Support Center (OSC)
Center (JIC)/ Joint Information Emergency Preparedness System (JIS)
On-Shift (EP) Functions Site Area Alert or Greater Alert or Greater Emergency (SAE) or Greater Augment w/in 60 Augment w/in 90 min.1, 2 min.1, 2 Augment w/in 60 min.3 Onsite FMT
- (1) Qualified individual to assess the protected area for radiation and contamination and provide input to the SRPC. Responsible for radiation protection coverage Offsite FMT B for the FMT as directed by SRPC * (1) Qualified (TSC) or Radiation individual to assess Protection Manager the area(s) outside (EOF). the protected area for radiation and
- (1) Driver to provide contamination, and transportation.
for radioactive plume tracking, as directed by, and Offsite FMT A under the control of, Field Monitoring Teams * (1) Qualified Not applicable the SRPC (TSC) or Not applicable (FMTs) individual to assess Radiation Protection the area(s) outside Manager (EOF).
the protected area Responsible for the for radiation and radiation protection contamination, and coverage of the for radioactive FMT as directed by plume tracking, as SRPC (TSC) or directed by, and Radiation Protection under the control of, Manager (EOF).
the SRPC (TSC) or Radiation Protection * (1) Driver to provide transportation.
Manager (EOF).
Responsible for the radiation protection coverage of the FMT as directed by SRPC (TSC) or Radiation Protection Manager (EOF).
- (1) Driver to provide transportation.
Emergency Operations Facility (EOF)/
Technical Support Center (TSC)/Operations Joint Information Support Center (OSC)
Center (JIC)/ Joint Information Emergency Preparedness System (JIS)
On-Shift (EP) Functions Site Area Alert or Greater Alert or Greater Emergency (SAE) or Greater Augment w/in 60 Augment w/in 90 min.1, 2 min.1, 2 Augment w/in 60 min.3 Media Information Staff to perform
- Manage and coordinate JIC/JIS staff to address Not applicable Not applicable JIC/JIS-related media information media inquiries.5 tasks.
related to the event.
Information Technology IT Lead (IT)6 IT Lead (TSC) (1)1 (EOF/JIC/JIS) (1)1
- Qualified individual
- Qualified functions rely on Not applicable Not applicable to ensure IT individual computer-based equipment is to ensure IT equipment, provide operable. equipment IT support. is operable.
1 Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time. A 10 CFR Part 50, Appendix E on-shift staffing analysis must be performed to support assignment of multiple roles to individual responders on-shift. For augmented ERO positions, a performance-based approach is acceptable for evaluating whether augmented personnel can adequately perform collateral functions without having competing priorities.
2 Specified TSC/OSC personnel should be capable of performing their required functions within 60(90) minutes of an Alert or higher EAL classification. Emergency response facility activation timing is not the concern; it is whether the facility staff is performing the stated function(s) within the time specified.
3 Specified EOF/JIC/JIS personnel should be capable of performing their required functions within 60 minutes of a SAE or higher EAL classification. Emergency response facility activation timing is not the concern; it is whether the facility staff is performing the stated function(s) within the time specified. Note: For JIC/JIS, licensees should use whatever term is used for the media support function/program/
location as applicable.
4 Two qualified radiation protection personnel for a single unit site or one per unit for a multi-unit site.
5 Does not need to be performed in the TSC/OSC, but function needs to be established at this point.
6 IT staff is only required to be described in the emergency plan if critical digital assets are identified per 10 CFR 73.54.