ML20207A968
| ML20207A968 | |
| Person / Time | |
|---|---|
| Issue date: | 05/21/1999 |
| From: | Obrien J NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9905280068 | |
| Download: ML20207A968 (16) | |
Text
n May 21, 1999
, MEMORANDUM TO: Thomas H. Essig, Chisf Emergency Preparedness and Health Physics Section Operating Licensing, Human Performance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation ,
FROM: James B. O'Brien, Emergency Preparedness Specialist originel signed byi Emergency Preparedness and Health Physics Section Operating Licensing, Human Performance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF APRIL 22,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING PROPOSED REVISION TO EMERGENCY PREPAREDNESS POSITION NO. 4 On April 22,1999, representatives of the Nuclear Energy Institute (NEI) and the nuclear power industry met with representatives of the Nuclear Regulatory Commission (NRC) to discuss NRC's proposed revision to Emergency Preparedness Position No.4, " Emergency Preparedness Position (EPPOS) on Emergency Plan and implementing Procedure Changes."
Attachment 1 is a list of participants. The NRC opened the meeting by describing the purpose of EPPOS in general and EPPOS No. 4 specifically. The purpose of EPPOS is to provide guidance to NRC inspectors on implementation of the emergency preparedness (EP) inspection program. EPPOS No. 4 provides guidance for inspectors reviewing licensees' emergency plan changes to determine whether the changes constitute a decrease in effectiveness.
The NEl and industry representatives discussed areas where the proposed EPPOS No. 4 should be revised. In addition, the NEl and industry representatives provided examples of changes which do not decrease the effectiveness of the plan for possible inclusion in the EPPOS (attached). The NRC identified some concerns with the examp'es, but acknowledged that they were useful in identifying areas for improving the EPPOS. In particular, the NRC acknowledged that clarification was needed regarding the review of emergency action levels.
Furthermore, the NRC acknowledged that work was needed to determine an approach for resolving concerns with the relocation of emergency plan commitments to emergency plan implementing procedures.
NEl stated it would provide written comments on the draft EPPOS No. 4. The NRC stated that it would consider revising EPPOS No. 4 based upon oral comments provided during the meeting and NEl's written comments when they are received. The NRC offered to discuss the g proposed final EPPOS No. 4 at the NEl Emergency Planning Information Conference in \ f June 1999.
Project No. 689 h((d y Attachments: As stated /0 cc w/att: See next page DISTRIBUTION: See attached page OFFICE EPS:EPfHP SC:EP&MP, NAME JO'Brik TEssig h DATE E/M /99 b/h/99 / /99 9905280068 990521 PDR REVGP ERGNUMRC PDR .
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_ Distributon: Mtg. Summiry w/ NEl R2 R: vision to EPPOS No. 4 Dited May 21, 1999 Hard Coov "M
PUBLIC EP&HP R/F '
. JO'Brien EMail SCollins/RZimmerman
. WKane BBoger TEssig FAkstulewicz EFox FKantor DBarss LCohen TMilligan RSullivan -
SRoudier GTracy, EDO 1
, Distnbution: Mtg. Summ ry w/ NEl Ra R; vision to EPPOS No. 4 D:ted May 21, 1999 Hard Cemy Docket File PUBLIC EP&HP R/F OGC ACRS SMagruder JO'Brien Eldall SCollins/RZimmerman WKane BBoger TEssig FAkstulewicz EFox FKantor DBarss i LCohen TMilligan RSullivan SRoudier GTracy, EDO I
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May 21,-1999
, MEMORANDUM TO: Thomas H. Essig, Ch'nf Emergency Preparedness and Health Physics Section
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Operating Licensing, Human Performance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation FROM: James B. O'Brien, Emergency Preparedness Specialist originsi signed by' Emergency Preparedness and Health Physics Section Operating Licensing, Human Performance and Plant Support Branch Division of Inspectir,n Program Management Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF APRIL 22,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING PROPOSED REVISION TO EMERGENCY PREPAREDNESS POSITION NO. 4 On April 2 ?,1999, representatives of the Nuclear Energy Institute (NEI) and the nuclear power industry n et with representatives of the Nuclear Regulatory Commission (NRC) to discuss NRC's pn. post d revision to Emergency Preparedness Position No.4, " Emergency Preparedness Position (EPPOS) on Emergency Plan and Implementing Procedure Changes."
Attachmont 1 is a list of participants. The NRC opened the meeting by describing the purpose of EPPOS in general and EPPOS No. 4 specifically. The purpose of EPPOS is to provide guidance to NRC inspectors on implementation of the emergency preparedness (EP) inspection l program. EPPOS No. 4 provides guidance for inspectors reviewing licersees' emergency plan I changes to determine whether the changes constitute a decrease in effectiveness.
The NEl and inductry representatives discussed areas where the proposed EPPOS No. 4 should be revised. In addition, the NEl and industry representatives provided examples of changes which do not decrease the effectiveness of the plan for possible inclusion in the 1 EPPOS (attached). The NRC identified some concems with the examples, but acknowledged that they were ursful in identifying areas for improving the EPPO5. In particular, the NRC acknowledged that ciarification was needed regarding the review of amergency action levels.
Furthermore, the NRC acknowledged that work was needed to detemine an approach for resolving concems with the relocation of emergency plan commitments to emergency plan implementing procedures.
NEl stated it would provide written comments on the draft EPPOS No. 4. The NRC stated that it would consider revising EPPOS No. 4 based upon oral comments provided during the meeting and NEl's written comments when they are received. The NRC offered to discuss the proposed final EPPOS No. 4 at the NEl Emergency Planning Information Conference in June 1999.
Project No. 689 Attachments: As stated cc w/att: See next page DISTRIBUTION: See attached page OFFICE EPS:EPfHP SC:EP&MP, NAME JO'Brik TEssig h DATE f/M /l[9 6/1A/99 / /99
' [
g UNITED 8 FATES NUCLEAR REGULATORY COMMISSION o WASHINGTON. D.C. 30006-00M e.,,, May 21, 1999 MEMORANDUM TO: Thomas H. Essig, Chief Emergency Preparedness and Health Physics Section Operating Licencing, Human Perfocnance and Plant Support Branch Division c' laspection Program Management -
Office of .': 'sar Reactor Regulation
/
FROM: James B. O'Brien, Emergency Preparedness Speciali g Emergency Preparedness and Health Physics Sect' /
'd Operating Licensing, Human Perfornance and P; ant upport Branch Division of Inspection Program Man.ngement Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF APRIL 22,1999. MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING PROPOSED REVISION TO EMERGENCY PREPAREDNESS POSITION NO. 4 On April 22,1990, representatives of the Nuclear Energy Institute (NEI) and the nuclear power industry met with presentatives of the Nuclear Regulatory Commission (NRC) to discuss NRC's proposed revis on to Emergency Preparedness Position No.4, " Emergency ,
Preparedness Position (EPPOS) on Emergency Plan and Implementing Procedure Changes." !
Attachment 1 is a list of participants. The NRC opened the meeting by describing the purpose of EPPOS in general and EPPOS No. 4 specifically. The purpose of EPPOS is to provide j guidance to NRC inspectors on implementation of the emergency preparedness (EP) inspection program. EPPOS No. 4 provides guidance for inspectors reviewing licensees' emergency plan changes to determine whether the changes constitute a decrease in effectiveness.
The 4El and industry representatives discussed areas where the proposed EPPOS No. 4 sho' Id be revised. In addition, the NEl and industry representatives provided examples of cht. reges which do not decrease the effectiveness of the plan for possible inclusion in the EFPOS (attached). The NRC identified some concems with the examples, but acknowledged that they were useful in identifying areas for improving the EPPOS. In particular, the NRC a:: knowledged that clarification was needed regarding the rev iw of emergency action levels.
p Furthermore, the NRC acknowledged that work was needed to determine an approach for resoMng concems with the relocation of emergency plan commitments to emergency plan implementing procedures.
NEl stated it would provide written comments on the draft EPPOS No. 4. The NRC stated that it would consider revising EPPOS No. 4 based upon oral comments provided during the i meeting and NEl's written comments when they are received. The NRC offered to discuss the proposed final EPPOS No. 4 at the NEl Emergency Planning Information Conference in June 1999.
Project No. 689 ,
Attachments: As stated cc w/att: See next page
7.
le i
. Nuclear Energy institute - ProJ::ct No. 689 o.
'cc: Mr. Ralph Boedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute
-Nuclear Energy institute Suite 400 Suite 400 1776 i Street, NW 1776 l Street, NW Washington, DC 20006-3708 l Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.
Suite 400 12300 Twinbrook Parkway, Suite 330 1776 l Street, NW . Rockville, Maryland 20852 l Washington,' DC 20006-3708 Mr. David Mod'een, Director
- - Engineering l Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 i Mr. Anthony Pietrangelo, Director
! Licensing -
l Nuclear Energy Institute l Suite 400
- 1776 i Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 l 1776 i Street, NW Washington, DC 20006-3708 i
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Attichm:nt 1 NRC/NEl MEETING ON NRCs PROPOSED REVISION TO EPPOS NO. 4 LIST OF ATTENDEES April 22,1999 l
NAME ORGANIZATION l Alan Nelson NEl l Bill Remz Virginia Power Merril Maddox Southern Nuclear l Nancy Chapman SERCH/Bechtel William Yarosz lilinois Power Thomas Essig NRC/NRR
! Jim O'Brien NRC/NRR Falk Kantor NRC/NRR Dan Barss NRC/NRR l
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Attachm:nt 2 NUCLEAR ENERGY INSTITUTE'S EXAMPLE OF EMERGENCY PLAN CHANGES WHICH DO NOT DECREASE THE EFFECTIVENESS OF EMERGENCY PLANS i
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Appendix 1 l Example Emergency Plan Changes Examoles of Channes Which Are Not Decreases in the Effectiveness of the Plan Example 4:
Licensee proposed to amend its NUREG-0737 Supplement I commitment to augment its staff with Core / Thermal Hydraulic Technical Support within 30 minutes. A review of technological advancements, e.g., the Safety Parameter Display System, capabilities of the on-duty Shift Technical Advisor, and expectations for the functional area during the 30 to 60 minute period determined the intended functions. This is not a decrease in effectiveness since an acceptable level of technical support was being maintained.
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Example Emergency Plan Changes
{rL E& amoles of Channes Which Are Not Decreases in the Effectiveness of the Plan Examnle 5:
The licensee proposed to modify the contents ofits health physics off-site monitoring emergency kits as listed in an appendix ofits plan. A review of the emergency plan implementing procedures for off-site monitoring determined that the list of emergency kit contents, as proposed, continued to provide the supplies necessary for performing off-site surveys. This is not a decrease in effectiveness the emergency kit's contents continued to satisfy 10CFR50.47(b)(8) standards and emergency kit contents continued to be listed in an emergency plan appendix per NUREG-0654 evaluation criteria.
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Example Emergency Plan Changes l, Examoles of Channes Which Are Not Decreases in the Effectiveness of the Plan l Exampici The licensee proposed to delete the storage of certain respiratory protection equipment in selected emergency response facilities. By using a combination of administrative controls (external exposure thresholds, Derived Air Concentration (DAC) hour tracking, ingestion of Potassium lodide, and relocation) respiratory protection equipment in selected facilities and by off-site teams is not required. The means for controlling radiological exposures includes exposure guidelines consistent with Environmental Protection Agency Emergency Worker and Lifesaving Activity Protective Action Guides. This is not a decrease in effectiveness since an acceptable level of worker protection was being maintained.
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Example Emergency Plan Changes
, lf Examnles of Channes Which Are Not Decreaces in the Effectiveness of the Plan U
Examnie 7:
i The licensee proposed to reorganize its emergency response organization by- '
Eliminating positions unrelated to core emergency response functions,~e.g., , redundant 1 clerical suppon, facility phone-talkers, etc.,
Reclassifying selected logistical suppon functions as non-emergency responders who would be called upon as needed through the company's normal organization structure, company meteorologist, company medical director, information technology coordinator, investor relations staff etc.,
Recategorizing selected first-tier positions (those defined as needed to activate emergency response facilities) as second-tier positions. These positions remain part of the emergency ;
response organization. '
These changes do not constitute a decrease in effecdveness since adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities remains available. None of the positions eliminated, reclassified or recategorized were committed to in response to NUREG-0737 Supplement I and none is considered essential for Operational Suppon Center, Technical Suppon Center or Emergency Operations Facility functionality. Therefore, the emergency planning standards continue to be maintained.
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Example Emergency Plan Changes Framnles of Channes Which Are Not Decreases in the Effectiveness of the Plan Examnle 8:
The licensee proposed to update selected EALs under provisions of 10 CFR 50.54(q) based on plant modifications:
. Changed threshold value for radiation monitor based on recalculation necessitated by equipment upgrade (the same calculational method was used to determine the threshold value, the resultant value changed because of differences in vendor-provided calibration sensitivity data)
Changed reference to Technical Specification release limit upon relocation ofinformation to Offsite Dose Calculation Manual Changed references to entry into the steam generator tube rupturc, emergency operating procedure with reference to steam generator tube rupture identified as being in progress These changes were evaluated to determine whether they ccnstituted a decrease in effectiveness of the classification scheme. It was concluded that the EALs, as changed, did not decrease the effectiveness of the emergency plan, and the plan continued to satisfy the 10CFR50.47(b)(4) emergency planning standard and the requirements of 10 CFR 50 Appendix E. Therefore, these C changes were implemented under provisions of 10 CFR 50.54(q). Discussion and agreement
( with the State and local governmental authorities was not required prior to implementation.
Approval by NRC was not required prior to implementation. Copies of revised documents were submitted in accordance with 10 CFR 50.4(b)(5).
Subsequently, these EALs were reviewd with the State and local governmental authorities on an annual basis.
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Example Emergency Plan Changes r
l Examoles of Channes Which Are Not Decreases in the Effectiveness of the Plan L -
Examnle 9:
l The licensee proposed to enhance selected EALs under provisions of 10 CFR 50.54(q) as i indicated below based on periodic procedure reviews, training, drills and exercises, and audits: l l
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Add noun-name references to radiation monitors previously described by component mark I numbers only Reorder list of stmetures cited in natural and destructive phenomena EALs so adjacent j structures are listed together !
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Add unit-specific electrical transformer identification to loss of power EALs ;
Replaced list of primary to secondary leakage Technical Specification limits with reference l to the applicable Technical Specification section Reworded EAL indication for the anticipated transient without trip site area emergency event for clarity (replaced negative statement " reactor power indication not decreasing" with
" manual reactor trip failed")
These changes were evaluated to determine whether they constituted a decrease in effectiveness of the classification scheme. It was concluded that the EALs, as changed, did not decrease the effectiveness of the emergency plan, and the plan continued to satisfy the 10CFR50.47(b)(4) emergency planning standard and the requirements of 10 CFR 50 Appendix E. Therefore, these changes were implemented under provisions of 10 CFR 50.54(q). Discussion and agreement with the State and local governmental authorities was not required prior to implementation.
Approval by NRC was not required prior to implementation. Copies of revised documents were submitted in accordance with 10 CFR 50.4(b)(5).
Subsequently, these EALs were reviewed with the State and local govemmental authorities on an annual basis.
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Example Emergency Plan Changes Examples of Chances Which Are Not Decreases in the Effectiveness of the Plan j
Examnle 10:
The licensee developed an emergency condition classification system in accordance with L NUREG-75/087, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear
! Power Plants. As required by Generic Letter 80-90, subject: Post TMI-Requimments, dated l October 31,1980, the licensee committed to a schedule for upgrading its emergency plan to l satisfy NUREG-0737 Action Item III.A.I.l. The licensee developed new EALs based on i
Revision I to NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of l Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" !
(Appendix 1, Basis for Emergency Action Levels for Nuclear Power Facilities).
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l These EALs were reviewed with the State and local governmental authorities on an annual basis. ;
Following issuance of the Emergency Preparedness Branch Position, subject: " Acceptable Deviations to Appendix 1 to NUREG-0654 Based Upon the Regulatory Analysis of l
- NUMARC/NESP-007 " Methodology for Development of Emergency Action Levels",in 1994 l
the licensee enhanced and clarified its site-specific EALs. As described in the Introduction Section of the branch position (EPPOS 1), the proposed revisions to the previously approved EAL scheme were discussed and agreed on by State and local governmental authorities prior to l
[ implementation. l l
( These EALs were reviewed with the State and local governmental authorities on an annual basis.
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Example Emergency Plan Changes Funmnles of Channes Which Are Not Decreases in the Effectiveness of the Plan Funmnie 11:
Emergency action levels were developed to implement the 10 CFR 50.47(b)(4) emergency planning standard: "[a] standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures." This initial set of emergency action levels (EALs) were developed based on Revision I to NUREG-0654/ FEMA-REP-1,
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (Appendix 1, Basis for Emergency Action Levels for Nuclear Power Facilities). These EALs were discussed and agreed on by State and local governmental authorities and approved by NRC.
l l Subsequently, these EALs were reviewed with the State and local governmental authorities on an
' annual basis.
Following issuance of Revision 3 to Regulatory Guide 1.101, Emergency Planning and -
Preparedness for Nuclear Power Reactors,in August 1992, the licensee proposed to revise their EAL classification scheme using NUMARC/NESP-007 (Revision 2, January 1992),
[t " Methodology for Development of Emergency Action Levels." As described in Part C (Regulatory Position) of RG-1.101, this proposed revision to the previously approved EAL l scheme was discussed and agreed on by State and local governmental authorities and approved I by NRC prior to implementation. j Subsequently, these EALs were reviewed with the State and local governmental authorities on an annual basis.
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