ML19084A257
| ML19084A257 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/21/2019 |
| From: | Balwant Singal Plant Licensing Branch IV |
| To: | Richardson M Pacific Gas & Electric Co |
| References | |
| L-2018-LLA-0248 | |
| Download: ML19084A257 (7) | |
Text
NRR-DMPSPEm Resource From: Singal, Balwant Sent: Thursday, March 21, 2019 4:39 PM To: Richardson, Michael Cc: Hoffman, Raymond; norris, michael
Subject:
Request for Additional Information - License Amendment Request (LAR) to Revise Emergency Plan Response Organization Staffing and Augmentation (EPID L-2018-LLA-0248)
Attachments: RAI-DC-EP Changes.docx By letter dated September 12, 2018 (Agencywide Documents Access and Management System (ADAMS)
Accession Number ML18255A368), Pacific Gas and Electric Company (the licensee) requested approval for an emergency plan change for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (DCPP). The proposed changes would revise the DCPP Emergency Plan to change the staffing and increase the staff augmentation times for certain emergency response organization positions.
The attached request for additional information (RAI) is necessary to facilitate the technical review being conducted by the U. S. Nuclear Regulatory commission staff. Draft RAI were issued on March 1, 2019. A clarification call was held on March 21, 2019 and it was agreed that the licensee will provide its response within 45 days of the issuance of the RAIs.
Please treat this email as transmittal of official RAIs. The email will be documented in ADAMS.
Thanks.
Balwant K. Singal Senior Project Manager (Diablo Canyon and Wolf Creek)
Nuclear Regulatory Commission Division of Operating Reactor Licensing Balwant.Singal@nrc.gov Tel: (301) 415-3016 Fax: (301) 415-1222 1
Hearing Identifier: NRR_DMPS Email Number: 882 Mail Envelope Properties (BN7PR09MB28515DC76F2E60D53E26956186760)
Subject:
Request for Additional Information - License Amendment Request (LAR) to Revise Emergency Plan Response Organization Staffing and Augmentation (EPID L-2018-LLA-0248)
Sent Date: 3/21/2019 4:39:24 PM Received Date: 3/21/2019 4:39:00 PM From: Singal, Balwant Created By: Balwant.Singal@nrc.gov Recipients:
"Hoffman, Raymond" <Raymond.Hoffman@nrc.gov>
Tracking Status: None "norris, michael" <Michael.Norris@nrc.gov>
Tracking Status: None "Richardson, Michael" <MJRm@pge.com>
Tracking Status: None Post Office: BN7PR09MB2851.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1173 3/21/2019 4:39:00 PM RAI-DC-EP Changes.docx 29054 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received: ZZZ
REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST REVISE EMERGENCY PLAN RESPONSE ORGANIZATION STAFFING AND AUGMENTATION DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NUMBERS 50-275 AND 50-323 By letter dated September 12, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML18255A368), Pacific Gas and Electric Company (PG&E) requested approval for an emergency plan change for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (DCPP). The proposed changes would revise the DCPP Emergency Plan to change the staffing and increase the staff augmentation times for certain emergency response organization (ERO) positions.
The request for additional information (RAI) listed below is necessary to facilitate the technical review being conducted by the U. S. Nuclear Regulatory commission (NRC) staff. A timely and thorough response to this draft RAI is requested to meet the approval date requested by the licensee.
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, Revision 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 License Amendment Request (LAR) to facilitate the NRC review.
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.
RAI-1
PG&E proposes to extend the augmentation timing of the Site Emergency Coordinator (SEC) at the Technical Support Center (TSC) and the Emergency Director (ED) at the Emergency Operations Facility (EOF) from 60-minute to 90 minutes responders. The justification provided is to have the Operations Advisor, who does not appear to be qualified as either a Shift Manager (SM) or an Emergency Director, report to the control room (CR) within 60 minutes from the declaration of an Alert or higher classification level, in lieu of the responding to the TSC. As such, the Operations Advisor does not appear to be relieving the SM of emergency plan functions.
Section 3.2.1.c of the Enclosure, Evaluation of Proposed Change, of the application states, in part:
In the proposed change, the Operations Advisor, a 60-minute response position, reports to the CR to provide on-shift support for plant operational oversight.
This change provides for specific support of command and control activities associated with plant operation, allowing the SM to focus on the event classification. With the removal of ancillary duties related to plant operations, the SM is able to maintain responsibility for event classification and direction of emergency response activities for an additional 30 minutes without conflicts.
Section 3.2.4.c of the Enclosure, Evaluation of Proposed Change, of the application states, in part:
Personnel filling the Operations Advisor position are current and/or former SRO
[senior reactor operator] license holders who fill plant management roles.
The guidance provided in RIS 2016-10 states:
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).
In addition, the guidance 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 classification level. It further provides a 60-minute augmenting Emergency Director position at the declaration of a Site Area Emergency or higher classification level.
- a. Please provide specific justification as to how relocating the Operations Advisor from the TSC to the Control Room adequately augments (relieves) 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).
- b. Additionally, please provide a justification that supports removing the Operations Advisor from the TSC. This justification should include a discussion on who will assume the tasks are currently being performed by the Operations Advisor in the TSC.
RAI-2
The proposed PG&E Table 5-1, DCPP on-Shift and Augmented ERO Minimum Staffing, removes one control room operator from the current DCPP emergency plan. Although this is a Plant Operations and Assessment of Operational Aspects position, no specific discussion or justification was provided in Section 3.2.1, Plant Operations and Assessment of Operational Aspects, of the functional analysis that justifies the removal of one control room operator.
Please provide a justification that supports the removal of one control room operator from the Plant Operations and Assessment of Operational Aspects Functional Area.
RAI-3
PG&E currently has the Shift Foreman/Shift Technical Advisor (STA) perform dose assessment in Quick mode, which uses a set of assumptions to perform dose assessment. The proposed change would extend the time of using the Quick mode of dose assessment from 60 minutes to 90 minutes. However, no justification was provided to support this change.
Please provide further justification that supports proposed extension of time that the Quick mode of dose assessment will be used. This justification should address both the accuracy of the dose assessment and the level of effort required to perform the Quick dose assessment 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).
RAI-4
PG&E currently has a Site Radiation Protection (RP) Coordinator performing the RP Supervisory Major Task in the Operations Support Center (OSC) within 60 minutes of the declaration of an Alert or higher classification level. The Site RP Coordinator response time was changed from 60 minutes to 90 minutes from the declaration of an Alert or higher classification level, and is included in the proposed Figure 4.3, OSC Organization. However, it is not included on Table 5-1, DCPP On-Shift and Augmented ERO Minimum Staffing, nor does the LAR did not provide a justification for the above changes.
- a. Please explain what DCPP design features or on-shift capabilities, that are unique to DCPP, support extending the augmentation time for the Site RP Coordinator from 60 minutes to 90 minutes from the declaration of an Alert or higher classification level. This explanation should be in addition to the improvements provided in the LAR that are typical to currently operating nuclear power plants, which were considered in the development of the revised Table B-1.
- b. If DCPP does not have design features or on-shift capabilities to support extending augmentation time of the Site RP Coordinator from 60 minutes to 90 minutes following the declaration of an Alert or higher classification level, then justify excluding a required 60-minute response position from the proposed Table 5-1, DCPP on-Shift and Augmented ERO Minimum Staffing.
RAI-5
PG&E proposes to extend the augmentation of the offsite survey teams from 60 minutes to 90 minutes following the declaration of an Alert or higher classification level based on the use of the DCPP real-time monitoring system combined with inputs from the onsite (out-of-plant) field monitoring team (FMT).
- a. Please provide a justification that DCPP has an appropriate number of detectors positioned to provide a reasonable indication of radiological releases.
- b. Please describe how these detectors could be used to assess the thyroid dose for event classification as approved in the DCPP emergency action scheme.
- c. Please explain how the onsite (out-of-plant) FMT can assess an ongoing radiological release for offsite consequences with an equivalent capability as the offsite FMT.
RAI-6
Section 3.2.5, Plant System Engineering, Repair and Corrective Actions Function of the Enclosure of the application states:
The proposed change maintains responsibility for core damage assessment with the Work Control Shift Foreman and extends augmented response of the Reactor, Electrical, and Mechanical Engineers by 30 minutes. Technological improvement in the DCPP data display systems via the PPC [plant process computer] provides a wide range of plant parameters and associated alarms with detailed trending capability to support rapid and continuous monitoring of plant conditions.
The guidance provided in RIS 2016-10 provides the following:
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 classification level.
Please provide further justification as to the necessary electrical and mechanical engineering expertise possessed by the Shift Foreman/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 Shift Foreman/STA is identified as the position on-shift to perform dose assessment, please provide further justification how providing this additional technical support impacts the ability to perform timely and accurate dose assessment.
RAI-7
The proposed PG&E Figure 5-3, OSC Organization, includes changes from the current DCPP Emergency Plan. Based on a review of the proposed Figure 5-3, it appears that DCPP proposes eliminate maintenance personnel while retaining their respective maintenance coordinators. However, the proposed Table 5-1, DCPP on-Shift and Augmented ERO Minimum Staffing, includes maintenance personnel and does not specifically identify maintenance coordinators. The staff could not identify a discussion that supported this change. Additionally, no discussion relative to the responsibilities of the maintenance coordinators was apparent in the Evaluation of Proposed Changes.
- a. Please provide justification for combining maintenance personnel with their respective maintenance coordinators. This justification should explain how the maintenance coordinators can perform both the maintenance technician role and the maintenance supervisor role for maintenance and troubleshooting activities as effectively as a maintenance technician and a maintenance supervisor.
- b. Please explain what controls are in place to ensure that the maintenance coordinators possess the requisite qualifications and proficiencies to perform the ERO functions of maintenance technicians and maintenance coordinators.
- c. Please explain why the maintenance coordinators are not identified on the proposed Table 5-1, since they are identified as responders within 60 and 90 minutes on Figure 5-3.
- d. Please provide a justification for removing the Mechanical Maintenance (operations) position from the Plant System Engineering, Repair, and Corrective Actions Functional Area.
- e. Please explain the basis why the Electrical/Instrument & Controls maintenance technicians were initial placed on-shift provide justification for why this basis is no longer valid.