ML19120A386

Request for Additional Information to Revise Emergency Plan Response Organization Staffing and Augmentation

ML19120A386
Person / Time
Site:	Ginna
Issue date:	04/30/2019
From:	V Sreenivas Plant Licensing Branch 1
To:	Gropp R Exelon Generation Co
Sreenivas V, NRR/DORL/LPL1, 415-2596
References
EPID L-2019-LLA-0053
Download: ML19120A386 (3)

Text

From: Sreenivas, V To: Gropp Jr, Richard W:(GenCo-Nuc)

Cc: Hodge, Jessie D:(GenCo-Nuc); Loomis, Thomas R:(GenCo-Nuc) (thomas.loomis@exeloncorp.com)

Subject:

GINNA: REQUEST FOR ADDITIONAL INFORMATION TO REVISE EMERGENCY PLAN RESPONSE ORGANIZATION STAFFING AND AUGMENTATION_EPID: L-2019-LLA-0053 Date: Tuesday, April 30, 2019 11:30:00 AM Please find the final requests for information (RAIs) that were developed based on the clarification call held on April 30, 2019. The licensee is here by requested to submit their responses by May 31, 2019. If you any questions, please contact the project manager at 301-415-2597 or by email v. sreenivas@nrc.gov REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO REVISE EMERGENCY PLAN RESPONSE ORGANIZATION STAFFING AND AUGMENTATION R. E. GINNA NUCLEAR POWER PLANT (DOCKET NUMBERS 50-244)

By application dated January 15, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML19017A136), Exelon Generation Company, LLC (Exelon, the licensee) submitted a license amendment request (LAR) for R.E. Ginna Nuclear Power Plant (Ginna). The proposed changes would revise the emergency response organization (ERO) staffing composition and increase staff augmentation times from 60 minutes to 90 minutes for certain ERO positions from the time of declaration of an Alert or higher emergency classification level. Additionally, the licensee proposed to relocate the listing of the ERO minimum staffing requirements from the respective site-specific annex for Ginna to the Exelon Standardized Radiological Emergency Plan. Some positions will also be designated as positions for full augmentation, rather than required minimum staffing positions, and relocated to an emergency plan implementing procedure (EPIP).

The requests for additional information (RAIs) listed below are necessary to facilitate the technical review being conducted by the U. S. Nuclear Regulatory commission (NRC) staff.

A timely and thorough response to these RAIs is requested to meet the approval date requested by the licensee.

RAI-1

Section 2.1.2, On-Shift ERO Revision Summary, of Enclosure 1 (Page 3 of 70),

Evaluation of Proposed Changes, shows one (1) Radiation Protection (RP) Technician on shift while the current Ginna Table 2.1 and Figure 2.1 show two (2) RP Technicians on shift (LAR Enclosure 1 pages 142 and 146).

Please clarify whether Ginna currently has 1 or 2 RP Technicians designated as onshift staff positions.

RAI-2

Section 3.1.1, Plant process Computer, of Enclosure 1 (Page 14 of 70) states:

Ginna also utilizes a Digital Plant Viewer (DPV) system that permits personnel to view conditions in the plant where cameras are installed live-

time prior to entry. The DPV also allows personnel to access live-time dose rate data in areas with installed Area Radiation Monitors (ARM). No RP Technician support is required to use DPV.

These statements appear to imply that cameras are installed as needed to support maintenance or normal plant activities but may not support all areas that may need access during accident conditions. Please clarify whether the Ginna permanently installed DPV system can be used to provide coverage for postaccident conditions that could require entry into a wide range of spaces with potentially changing radiological conditions.

Please explain level of coverage of installed radiation monitors for areas that may be affected by changing radiological conditions and require entry during an event.

Please explain how RP coverage can be provided using the DPV system without RP Technician support as noted above.

Please describe the electrical power reliability of DPV system for design basis accidents.

RAI-3

Section 3.2.3, EP Function: Radiation Protection, of Enclosure 1 (Page 24 of 70) states:

The RP function includes the following tasks as defined in NRCs Alternative Guidance:

Provide qualified radiation protection coverage for responders accessing potentially unknown radiological environments during emergency conditions.

Provide in-plant surveys.

Control dosimetry and radiologically controlled area access.

The ability to provide radiological expertise when the plant is experiencing an event with serious radiological consequences is crucial, due to the unknown radiological environment faced by emergency workers, particularly at the onset of the event.

Additionally, Section 3.2.3 of Enclosure 1 (Page 26 of 70) states that two (2) of the 90-minute augmenting RP personnel responders will be task-qualified (i.e., qualified to assess radiation and contamination levels) but will not necessarily be an ANSIqualified RP Technician). The two additional Task Qualified personnel will be under the direction and supervision of an RP Lead Technician.

Section 2.4.3, Radiation Protection (RP), of the technical basis for the proposed guidance for NUREG-0654,Section II.B, Emergency Response Organization, (ADAMS Accession No. ML16117A427) states in part, The augmentation (support) of this position should occur in two stages: within 60 minutes of an Alert ECL [emergency classification level] or greater, 3 additional qualified RP staff should be available, and within 90 minutes of an Alert ECL or greater, an additional 3 additional qualified RP staff should be available, and both are typically staffed in the OSC [Operations Support Center]. The total number of

qualified RP staff recommended for the ERO is 8 for a single unit site, or 6 plus 1 for each unit.

a. Please explain what Ginna design features or onshift capabilities that are unique to Ginna, support replacing two (2) qualified RP Technicians with two (2) personnel, who will be task-qualified (i.e., qualified to assess radiation and contamination levels) but will not necessarily be an ANSIqualified RP Technician. 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, as well as the fact that Ginna is a single unit plant.

b. Please describe how the augmenting RP personnel responders, who will be task-qualified (i.e., qualified to assess radiation and contamination levels), are trained to perform each of the above listed RP tasks. Specifically, what formal training process is in place for task-qualified personnel, in lieu of qualified RP technician process, to ensure personnel are proficient in providing adequate radiation protection coverage during an emergency for responders accessing in-plant areas with potentially unknown or changing radiological environments to perform mitigation and repair activities.

RAI-4

Section 3.2.11, EP Function: Field Monitoring Teams (FMTs), of Enclosure 1 (page 50 of

70) states, Onsite Field Monitoring - The current Ginna Emergency Plan designates two (2) RP personnel as Minimum Staff for the EP function of On-site Surveys. The proposed changes to the Ginna Emergency Plan designate one (1) task qualified person for on-site surveys.

However, the table on Page 6 of 70 provides the following:

Onsite Monitoring Team Member #1 No Change Onsite Monitoring Team Member #2 Changed to RP Tech #3 RP Personnel #1 (In-Plant Surveys) RP Tech #3

Please clarify the composition of the person(s) filling the function of the Onsite Field Monitoring.