ML19058A359
| ML19058A359 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/2019 |
| From: | O'Banion M Plant Licensing Branch IV |
| To: | Hicks J TEX Operations Company |
| References | |
| L-2018-LLA-0299 | |
| Download: ML19058A359 (6) | |
Text
1 NRR-DMPSPEm Resource From:
O'Banion (Watford), Margaret Sent:
Wednesday, February 27, 2019 9:42 AM To:
Hicks, Jack Cc:
RidsNrrPMComanchePeak Resource
Subject:
Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 - Final Request for Additional Information Concerning License Amendment Request to Revise the Emergency Plan (EPID L-2018-LLA-0299)
Final Request for Additional Information On February 21, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff sent Vistra Operations Company LLC (Vistra OpCo) the draft Request for Additional Information (RAI) provided below. This RAI relates to a license amendment request that revises the Emergency Plan for Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2.
During a clarification call on February 27, 2019, Vistra OpCo informed the NRC staff that the information requested by the NRC staff was understood. Mr. Jack Hicks of Vistra OpCo agreed to provide a response to this final RAI by March 29, 2019. The NRC staff also informed the licensee that a publicly available version of this final RAI would be placed in the NRCs Agencywide Documents Access and Management System.
By letter dated October 31, 2018 (Agencywide Documents Access and Management System (ADAMS)
Package Accession No. ML18309A320), Vistra Operations Company LLC (the licensee) requested a license amendment to revise the Emergency Plan for Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2. The proposed amendment requests to extend staff augmentation times and reduce the number of required Emergency Response Organization positions. The U.S. Nuclear Regulatory Commission (NRC) staff requires additional information to complete its review of this request as detailed below Background Information The emergency plan regulations in Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(2) state, in part, that on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times,
[and] timely augmentation of response capabilities is available The guidance in Table B-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies, to Revision 1 of NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (ADAMS Accession No. ML040420012), provides an acceptable means of meeting planning standard 10 CFR 50.47(b)(2).
Subsequently, the NRC issued Regulatory Issue Summary (RIS) 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (ADAMS Accession No. ML16124A002), to further inform licensees of the application of Table B-1 to NUREG-0654/FEMA-REP-1 (Revision 1) in support of license amendment requests to change augmenting ERO staffing and response times. In addition,, RIS 2016-10 clarified the application of the Nuclear Energy Institute (NEI) document NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, dated June 2011 (ADAMS Accession No. ML111751698), in justifying proposed changes to ERO staffing and response times. In addition to the clarification this RIS provides, the RIS will assist licensees by providing examples of the scope and detail of information that should be provided in the LARs to facilitate the NRC review.
2 The NRC further issued alternative guidance for licensee EROs by letter dated June 12, 2018 (ADAMS Accession No. ML18022A352), hereafter referred to as the revised Table B-1. The revised ERO staffing guidance will be included in the pending revision to NUREG-0654/FEMA-REP-1.
CPNPP-RAI-1 Section 3.2.2, Emergency Direction and Control, of Attachment I, Evaluation of Proposed Change, of the application, states, in part, As described earlier, the advances in technology, training, and procedures, as well as the additional on-shift Operations personnel, adequately compensate for any burden imposed on the Shift Manager for an additional 20 minutes.
The guidance provided in RIS 2016-10 states, in part, A licensee requesting a change in staff augmentation requirements that would have the lead manager unavailable to assume command and control within 60 minutes of the initial emergency declaration should show that the on-shift staff includes enough qualified supervision such that one supervisor will assume the emergency director role. The licensee should show that the on-shift supervisor performing the manager actions will not have any additional duties (e.g., each unit under the direction of a unit supervisor, a shift manager providing oversight of the plant response, and a designated emergency director responsible for emergency plan implementation).
The guidance provided in the revised Table B-1 provides for a 60-minute augmenting Emergency Coordinator position to provide augmentation (relief) for the on-shift Command and Control position at the declaration of an Alert or higher emergency classification level. It further provides a 60-minute augmenting Emergency Director position at the declaration of a Site Area Emergency or higher emergency classification level.
Please provide specific justification as to how these specific advances in technology, training, and procedures, as well as the additional on-shift Operations personnel, adequately augment (relieve) the Shift Manager position from providing oversight of the plant response to allow for performance of Emergency Coordinator responsibilities for emergency plan implementation for the additional timing requested, consistent with the guidance in RIS 2016-10 and the revised Table B-1, which serve as an acceptable means of meeting planning standard 10 CFR 50.47(b)(2).
CPNPP-RAI-2 Section 3.2.3, Communications, of Attachment I of the application, states, in part, CPNPP Emergency Plan, Table 1.1 currently requires one (1) dedicated on-shift communicator and one (1) on-shift communicator who can be assigned other functions to act as ENS Communicator. Two (2) augmenting Communicators currently report to the TSC within 70 minutes. The proposed change would extend the TSC Communicators' response time to 90 minutes and combine the on-shift Communicator functions into one (1) position.
The guidance provided in RIS 2016-10 provides the following, in part, To adequately support the elimination or extension of the two 60-minute responders, the licensee should show that two on-shift positions are identified to fill the 60-minute responders role to Notify licensee, State, local and Federal personnel [and] maintain communication. The licensee should show that these positions are not assigned other tasks that may prevent the timely performance of their assigned notification or communication functions, as specified in the emergency plan. The licensee should discuss how communication technologies employed by the proposed on-shift staff will support timely, effective, and reliable notifications. Additionally, the communications technologies should be referenced in the emergency plan to ensure that
3 future changes are reviewed using the RG [Regulatory Guide] 1.219 [Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Revision 1 (ADAMS Accession No. ML16061A104)] change process, as they were used as the basis for the proposed change.
The guidance provided in the revised Table B-1 provides for two 60-minute augmenting communicators to provide augmentation (relief) for the on-shift Communicator position at the declaration of an Alert or higher emergency classification level. It further provides a 60-minute augmenting Communicator position at the declaration of a Site Area Emergency or higher emergency classification level.
Although the use of technological improvements can be used to justify the reduction in on-shift Communicator staffing performing off-site notifications, it does not provide justification for the extension in timing for augmentation of additional communicators.
Please provide specific justifications as to why the requested additional timing of the transfer of the notification responsibilities from the Control Room is not an additional burden to the on-shift staffing, consistent with the guidance in RIS 2016-10 and the revised Table B-1, which serve as an acceptable means of meeting planning standard 10 CFR 50.47(b)(2). Additionally, the specific communication technologies should be referenced in the emergency plan to ensure that future changes are reviewed 10 CFR 50.54(q) change process, if they are used as the basis for the proposed change.
CPNPP-RAI-3 Section 3.2.7, Station System Engineering, of Attachment I of the application, states, in part, The Shift Technical Advisor (STA) is the on-shift position assigned for technical support. The STA functions in an oversight role for accident assessment and evaluation of operating conditions, providing the core/thermal hydraulic technical support function on shift. The STA performs assigned technical support activities required by operating procedures, Technical Specifications, and emergency implementing procedures. A review of procedural actions for this position demonstrated that failed fuel determinations, as well as establishing recovery/reentry priorities, would not be required until augmenting staff arrives.
The guidance provided in RIS 2016-10 provides the following, in part, To adequately justify an extension of these responders, the licensee should show that on-shift positions are capable of filling these roles during the 90-minute period after an emergency declaration. This will require a review of site procedures to identify the technical support tasks requiring electrical and mechanical expertise that must be performed within the first 90 minutes of an emergency. The licensee should then show that there are on-shift positions with the necessary expertise to perform the identified technical support functions, and that such performance will not prevent the timely performance of their other assigned functions, as specified in the emergency plan Additionally, the change justification should address the ability of on-shift positions to perform troubleshooting activities without interfering with their primary emergency response duties (e.g.,
on-shift electrical or mechanical maintenance personnel with supervisory personnel to provide oversight).
The guidance provided in the revised Table B-1 provides for three (3) 60-minute augmenting Engineering staff to provide augmentation (relief) for the on-shift engineering position at the declaration of an Alert or higher emergency classification level.
Please provide further justification as to the necessary electrical and mechanical engineering expertise possessed by the STA to perform technical support functions for the additional timing requested, consistent with the guidance in RIS 2016-10 and the revised Table B-1, which serve as an acceptable means of meeting planning standard 10 CFR 50.47(b)(2). Additionally, as the STA is identified as the position on-shift to perform
4 dose assessment, please provide further justification how providing this additional technical support impacts the ability to perform timely and accurate dose assessment.
CPNPP-RAI-4 Section 3.2.8, Radiological Assessment, of Attachment I of the application, states, in part, The TSC Onsite Radiological Assessment Coordinator assumes dose assessment responsibilities from on-shift personnel. The proposed change would extend the augmentation time from 40 to 60 minutes. Improvements in the dose assessment processes as described earlier ensure that the extended augmentation time will not impact this functional area.
Section 3.1.2, Dose Assessment, of Attachment I of the application, states, in part, Over the years, modifications and upgrades have improved the availability, speed, and reliability of the dose assessment program. The dose assessor can obtain system parameters from the PCS [Plant Computer System], radiation monitor instrument readings from the Radiation Monitoring System (RMS), or results from in-plant sampling for input into the dose assessment software.
Please provide further description of the dose assessment program, specifically how the system operates (i.e.,
whether it automatically downloads inputs from the radiological and metrological monitors and continuously develops dose assessments, or whether it is only operated manually and would require more operator action) to ensure the timely performance of offsite dose assessment consistent with the guidance in RIS 2016-10 and the revised Table B-1, which serve as an acceptable means of meeting planning standard 10 CFR 50.47(b)(2).
CPNPP-RAI-5 Section 3.2.8, Radiological Assessment, of Attachment I of the application states, in part:
The CPNPP Emergency Plan, Table 1.1 lists two Radiation Protection (RP) Technicians responding in 40 minutes to perform offsite surveys. The proposed change extends the augmentation time to 60 minutes and retitles the position as Monitoring Team, which allows the positions to be filled by a trained individual. It further states, in part, that two Vehicle Drivers augment in 70 minutes and this timing is proposed to be extended to 90 minutes.
The guidance provided in the revised Table B-1 provides for an Onsite Field Monitoring Team (FMT) and an Offsite FMT augmenting in 60-minutes, and an additional Offsite FMT augmenting in 90 minutes, with each FMT comprised of one qualified monitoring individual and one Vehicle Driver.
Based on having the RP Technicians and the Vehicle Drivers augmenting at different times, please provide justification as to how FMTs will be adequately mobilized to perform field monitoring at 60 minutes and 90 minutes, consistent with the guidance in RIS 2016-10 and the revised Table B-1, which serve as an acceptable means of meeting planning standard 10 CFR 50.47(b)(2).
CPNPP-RAI-6 Section 3.2.8, Radiological Assessment, of Attachment I of the application states, in part:
The tasked qualified personnel assigned to the Monitoring Teams will be under the control of a fully-qualified senior RP [Radiation Protection] personnel at all times. Additionally, it states that the TSC Onsite Radiological Assessment Coordinator assumes dose control responsibilities from onshift personnel with a proposed augmentation time of 60 minutes.
The guidance provided in the revised Table B-1 provides that qualified individuals assigned to the FMTs will be under control of a senior RP personnel at all times.
5 Please clarify that the TSC Onsite Radiological Assessment Coordinator will be responsible for the radiological health and safety of the FMTs, consistent with the guidance in RIS 2016-10 and the revised Table B-1, which serve as an acceptable means of meeting planning standard 10 CFR 50.47(b)(2).
CPNPP-RAI-7 Section 3.2.8, Radiological Assessment, of Attachment I of the application states, in part:
The proposed change will extend the augmentation time for two RP Technicians to 60 minutes. Additionally, it reduces the 70 minute augmenting RP Technicians from five to three and extend the augmentation timing for those three to 90 minutes.
The guidance provided in the revised Table B-1 provides for three augmenting RP Technicians at 60 minutes and an additional three RP Technicians augmenting at 90 minutes.
Please provide further justification as to why the proposed change for augmentation of RP Technicians, which is not consistent with the guidance provided in the revised Table B-1, serves as an acceptable means of meeting planning standard 10 CFR 50.47(b)(2).
CPNPP-RAI-8 Section 3.2.9, System Corrective Action, of Attachment I of the application states, in part:
The CPNPP on-shift complement includes a mechanic, an electrician, and an Instrument &
Controls (I&C) technician to perform emergency repairs, with augmentation of additional mechanic, electrician, and an I&C technician within 70 minutes. The proposed change would extend the augmentation time of those additional maintenance personnel from the existing 70 minutes to 90 minutes. The proposed change will also remove the onshift mechanic, electrician and I&C technician, and have on-shift maintenance revert to being performed by personnel assigned other functions.
The revised Table B-1 calls for a 60-minute augmentation time of (1) mechanic and (1) electrician followed by a 90-minute augmentation time for (1) I&C technician in order to perform repair activities.
The guidance provided in RIS 2016-10 provides the following:
To adequately support an extension of the response time for these responders, the licensee should demonstrate that the responsibilities of these positions can be covered with on-shift staff or earlier responders.
Please justify why the requested staffing of maintenance personnel, which is not consistent with the guidance provided in RIS 2016-10 or the revised Table B-1, serves as an acceptable means of meeting planning standard 10 CFR 50.47(b)(2).
Thank you, Maggie OBanion Project Manager, Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Phone: 301-415-1233 Email: Margaret.OBanion@nrc.gov
Hearing Identifier:
NRR_DMPS Email Number:
833 Mail Envelope Properties (SN6PR09MB28483D2B295D163E8ECBA361AD740)
Subject:
Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 - Final Request for Additional Information Concerning License Amendment Request to Revise the Emergency Plan (EPID L-2018-LLA-0299)
Sent Date:
2/27/2019 9:42:16 AM Received Date:
2/27/2019 9:42:00 AM From:
O'Banion (Watford), Margaret Created By:
Margaret.O'Banion@nrc.gov Recipients:
"RidsNrrPMComanchePeak Resource" <RidsNrrPMComanchePeak.Resource@nrc.gov>
Tracking Status: None "Hicks, Jack" <Jack.Hicks@luminant.com>
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