ML20293A075
| ML20293A075 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 10/14/2020 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | Enfinger T, Joyce R, Lowery K Southern Nuclear Operating Co |
| References | |
| L-2020-LLA-0150, L-2020-LLA-0151 | |
| Download: ML20293A075 (14) | |
Text
From: Lamb, John Sent: Wednesday, October 14, 2020 12:29 PM To: Lowery, Ken G.; Joyce, Ryan M.; Enfinger, Timothy Lee
Subject:
RAIs for SNC Fleet EP LAR (L-2020-LLA-0150 and L-2020-LLA-0151)
Importance: High Ken, Ryan, and Tim, By application dated June 30, 2020 (Agencywide Document Access and Management System (ADAMS)
Accession No. ML20192A140), as supplemented by letter dated August 11, 2020 (ADAMS Accession No. ML20224A464), Southern Nuclear Operating Company (SNC, licensee) submitted changes to revise the SNC Standard Emergency Plan (SEP) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2; the Joseph M.
Farley Nuclear Plant, Units 1 and 2; and the Vogtle Electric Generating Plant, Units 1, 2, 3 and 4, for Commission review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes would change the emergency response organization (ERO) staffing composition and extend staff augmentation times from 75 to 90 minutes.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed your application and determined that additional information is needed to complete its detailed technical review to make an independent assessment regarding the acceptability of the proposed exemptions in terms of regulatory requirements. Below are the requests for additional information (RAIs).
On October 1, 2020, the NRC staff provided draft RAI questions to SNC to make sure that the RAIs are understandable, the regulatory basis is clear, to ensure there is no proprietary information, and to determine if the information was previously docketed. On October 6, 2020, SNC requested a clarifying call with the NRC staff. On October 14, 2020, a clarifying call between the NRC staff and the SNC staff was held. SNC stated that SNC would provide the RAI response on Friday, November 20, 2020.
If you have any questions, you can contact me at 301-415-3100.
Sincerely, John REQUEST FOR ADDITIONAL INFORMATION By application dated June 30, 2020 (Agencywide Document Access and Management System (ADAMS)
Accession No. ML20192A140), as supplemented by letter dated August 11, 2020 (ADAMS Accession No. ML20224A464), Southern Nuclear Operating Company (SNC, licensee) submitted changes to revise the SNC Standard Emergency Plan (SEP) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2; the Joseph M.
Farley Nuclear Plant, Units 1 and 2; and the Vogtle Electric Generating Plant, Units 1, 2, 3 and 4, for Commission review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes would change the emergency response organization (ERO) staffing composition and extend staff augmentation times from 75 to 90 minutes.
Applicable Regulatory Requirements / Guidance
- 1. Planning Standard (b)(2) to 10 CFR 50.47, which states:
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, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
- 2.Section II.B to NUREG-0654/FEMA-REP-1 (NUREG-0654), Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants
- 3. 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 inform licensees of the application of guidance documents to support license amend requests to change augmenting ERO staffing and response times.
RIS 2016-10 states in part:
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.
Concerning the Emergency Operations Facility Director Per the guidance in NUREG-0654, Table B-1, an augmented Senior Manager should fulfill the Emergency Operations Facility Director major task at 60 minutes. 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).
Concerning Technical Support Table B-1 of NUREG-0654 assigns the major task of Technical Support to the Shift Technical Advisor on-shift to perform core damage assessments and additional support with one individual within 30 minutes. To adequately support an elimination or extension of the one 30-minute technical support responder, the licensee should show that an on-shift position is identified as capable of initially filling the 30-minute responders role of Core/Thermal Hydraulics. Typically, this position will be the shift technical advisor. The licensee should show that this position has the necessary expertise with core/thermal hydraulics and possesses the ability to offer adequate functional oversight to assess core conditions. The licensee should also show that the augmenting staff with core/thermal hydraulics expertise will be available within
an appropriate time frame. NRC staff will review whether the justification identifies procedure and information technology advances since the implementation of NUREG-0654 such as improvements that allow using a symptom-based emergency operating procedure network, and computerized or automated systems for the acquisition and display of parameters used to evaluate core conditions.
Per the guidance of NUREG-0654, Table B-1, Electrical and Mechanical expertise should be provided by two 60-minute responders under the Technical Support major task. 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.
The justification should identify procedure, training and information technology advances made since the implementation of NUREG-0654 that facilitate technical support assessments by on-shift personnel or obviate the need for such assessments within 90 minutes of an emergency declaration. 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).
- 4. Prior NRC approval of the SNC Standard Emergency Plan and Site-Specific Annexes The NRC staff previously reviewed and approved the ERO staffing composition and staff augmentation times in letter dated March 14, 2017 (ADAMS Accession No. ML16141A090). As part of its review of this LAR, the NRC staff reviewed the basis and justification used previously by SNC for the changes to ERO staffing composition and staff augmentation times.
Requests for Additional Information (RAIs)
The NRC staff has reviewed the LAR, as supplemented, and determined that additional information is needed to complete the review, as indicated in the RAIs below.
RAI 1
Section 3.1, Enhancements, of the supplement provided a discussion of several equipment upgrades that, in part, support SNCs proposed changes to the SNC SEP. However, the NRC staff requires additional information to justify the use of certain enhancements.
- a. SNC asserts that the improved remote monitoring that uses expanded Wi-Fi and 900 MHz radio systems to provide radiation protection (RP) personnel with the capability to remotely monitor individuals using their electronic dosimeters at a central monitoring station. In addition, SNC asserts that the Emergency Director has both real time visual monitoring of key emergency plan equipment and dose rates.
- i. Are these cameras permanently located in positions that would be effective in supporting troubleshooting/repair activities for conditions that could during a radiological emergency?
ii. Although the NRC staff does understand how a video of certain events, such as flooding or a fire, could explain why emergency core cooling (ECCS) equipment was not functioning, troubleshooting would not seem appropriate for equipment subject to those types of events or other failures that would be readily apparent by video observation. As such, explain how a video of equipment that is not functioning as expected could effectively support troubleshooting by the Emergency Director.
iii. Does the improved system provide the Emergency Director with dose rates for areas with key emergency plan equipment?
iv. The Supplement states, [t]his effectively allows all individuals wearing electronic dosimeters to be remotely monitored and provides RP with immediate indication of dose rates throughout the plants.
- What is meant by effectively?
- Are all on-shift personnel assigned these remotely monitored electronic dosimeters?
- Are radiation work permits (RWPs) with higher emergency dose rates and dose limits available for on-shift personnel to use and are all personnel who would reasonably be expected to enter radiologically controlled areas in response to a radiological event trained on their use?
- Does this system rely on electronic dosimeters issued to response personnel to provide an indication of dose rates?
- Are these dose readings available for the Emergency Director to view in real time?
- b. Please explain what measures are in place to ensure the Wi-Fi and 900 MHz radio systems will be maintained in an appropriate manner for equipment that supports the SNC SEP.
- c. Explain how SNC ensures that the Wi-Fi and 900 MHz radio systems, including power supplies and the central monitoring station, are reliable.
- d. Does the use of these systems require the full attention of one of the on-shift RP personnel to monitor personnel at the central monitoring station during an event?
- e. How are effective communications maintained between the on-shift RP personnel at the central monitoring station and the Emergency Director?
- f. Concerning the improved communications systems with defined bridge lines, address the following:
- i. Explain how communications, using defined bridge lines, will be established between onsite personnel and ERO augmentation personnel who are in route to the facility.
ii. Explain what specific mobile communication improvements SNC has implemented and that will support communication with the augmenting ERO members as they are in route to the site.
iii. Does Common hands-free technologies with mobile phones refer to SNC issued phones, or with typical mobile phones?
iv. Does SNC expect the ERO to engage in emergency response-related discussions while in route to the site? If so, is there a dedicated individual on-shift who will perform these communications?
- v. Have these improved communication capabilities been demonstrated by drill performance?
- g. Concerning improved document and record retrieval, for engineers travelling to the site, will there be additional engineers who would be available to use remote document and record retrieval from a remote location and be capable of providing engineering support?
- h. Concerning procedural improvements, address the following:
- i. Considering that current SNC staffing is based, in part, on previously provided procedural improvements and equipment modifications, describe what significant modifications and procedure changes have been made since the system based approach described on pages E10-17 of ML15246A059 for Vogtle 1&2, pages E7-17 for of ML15246A053 for Hatch, and pages E4-17 of ML15246A050 for Farley.
ii. Explain how these changes directly allow for more efficient implementation of emergency plan troubleshooting and repair functions.
RAI 2
Concerning the use of on-shift Senior Reactor Operators (SROs), who are trained as Emergency Directors, as a basis to support extending the Emergency Director augmentation response time, address the following:
- a. Table 2.2.A, [Site-Specific] On-Shift Staffing, Note 1, states Two Shift Supervisors are assigned to oversight of each Unit, but they can provide support to the ED [Emergency Director] without conflicting duties. Are there two Shift Supervisors assigned oversight of each Unit, for a total of four Shift Supervisors?
- b. In addition to training as Emergency Directors, as provided in the Supplement, are all SROs qualified and evaluated as Emergency Directors?
- c. Does SNC intend to have an on-shift Shift Supervisor, who is not assigned any duties that would preclude him from becoming an Emergency Director, relieving the Shift
Manager of Emergency Director duties within 60 minutes of the declaration of an Alert or greater classification level?
If SNC does not intend to have one Shift Supervisor or Emergency Director relieve the Shift Manager at 60 minutes of the declaration of an Alert or greater classification level, then explain who will relieve the Shift Manager of either the Shift Manger or Emergency Director responsibilities at 60 minutes of the declaration of an Alert or greater classification level or provide an alternative solution.
- d. If SNC does not intend to provide augmentation for the Emergency Director for 90 minutes of the declaration of an Alert or greater classification level, then explain what unique SNC design characteristics support this reduction in effectiveness. These characteristics should be beyond the capabilities of typical operating reactors as these capabilities are subsumed in Table B-1 of NUREG-0654.
RAI 3
As provided in the LAR, as supplemented, the two on-shift Radiation Protection (RP) Technicians are assigned the following emergency plan tasks:
- RP coverage for troubleshooting/repair team actions,
- Plant surveys,
- Protected area surveys (out-of-plant),
- Supporting movement of security personnel due to radioactive release,
- Offsite field monitoring,
- Issue dosimetry,
- Establish Radiation Work Permit (RWP) requirements,
- Develop dose extension documents, and
- Brief individuals on potassium iodide (KI) and provide documentation to the Emergency Director for KI issuance.
Explain what unique SNC plant characteristics, not typical of current operating nuclear power plants, justify the elimination of one on-shift RP technician and extending the augmentation time of three RP Technicians from 60 minutes to 90 minutes of the declaration of an Alert or greater classification level. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 4 , Supplemental Analysis Table, of the supplement states, in part:
First, augmentation of on-shift personnel with two Field Monitoring Teams [FMTs]
will be at 90 minutes rather than one at 60 and the other at 90 minutes. Second, a dedicated on-site out-of-plant FMT will not be used, but rather SNC will use one of the two on-shift RP Technicians for this function as directed by the ED based on priorities for the 60-90 minute interim time period.
SNC has concluded that providing one offsite FMT for the period from 60-90 minutes is not necessary.
However, the original basis for the previous approval of the ERO staffing composition and staff augmentation times stated, in part [similar wording was used for each safety evaluation]:
As part of the proposed HNP [Hatch Nuclear Plant] SEP Annex, the on-shift staffing for the onsite/out-of-plant survey will be performed by a single RP technician or other appropriately trained individual.
The HNP Emergency Plan, Revision 36, provides for an on-shift offsite survey team and an augmented offsite survey team reporting within 75 minutes of declaration of an Alert or higher classification. The proposed staffing for the SNC SEP augments a single offsite survey team within 75 minutes of an Alert or higher clarification and maintains the augmentation by the EOF [Emergency Operations Facility] Field Team Coordinator and Field Team Communicator positions, as currently provided.
Since the original basis to extend the ERO augmentation times to 75 minutes was due in part to having the capability of the on-shift RP staffing to perform some type of field monitoring and this capability is removed in the proposed staffing, provide a justification that supports eliminating the capability to perform field monitoring at 60 minutes after the declaration of an Alert or greater classification level.
RAI 5
Table B.1 of NUREG-0654 provides that the Shift Manager/Emergency Director is the on-shift individual who performs the Supervision of RP Staff and Site RP function until relieved of that function by a Site Radiation Protection Coordinator [RP Supervisor/Manager] at 60 minutes of the declaration of an Alert or greater classification level. Based on a review of the LAR, as supplemented, the NRC staff could only identify dose assessment, on-site protective actions, and the need for on-site/out-of-plant surveys oversight as RP Supervisor responsibilities.
Provide clarification as to where the RP Supervisor responsibilities are clearly articulated in the SNC Standard Emergency Plan. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 6
Provide a justification that supports replacing a qualified RP Supervisor/Manager with a Shift Manager from 60 minutes to 90 minutes after the declaration of an Alert or greater classification level. This justification should indicate that the Shift Manager, in addition to his Shift Manager and Emergency Director qualifications, is qualified as a RP Supervisor. This justification should also clearly demonstrate that the Shift Manager/Emergency Director can perform the RP Supervisor/Manager Function concurrent with Emergency Director and Shift Manger functions for an extended time. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 7
Considering that the current and proposed SNC ERO augmenting positions for dose assessment include a RP Supervisor at the Technical Support Center (TSC) and two Dose
Assessment Supervisor & Analysts at the EOF, it appears that the SNC ERO, as augmented, has more capability to provide dose assessment to the Emergency Director than an on-shift Chemistry Technician or other trained individual.
Explain how the on-shift Chemistry Technician, or other trained individual, can provide equivalent dose assessment information as the augmenting ERO organization for an additional 15 minutes. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 8
Please provide clarification regarding the following SNC SEP Table 1 position titles, as it was not clear to the NRC staff what individuals and/or what qualifications were required of those individuals to staff these positions:
- Two Dose Assessment Supervisor & Analysts at the EOF,
- FMT Coordinator and Communicator at the Operations Support Center (OSC),
- The Offsite Response Organization Coordinator and News Writer at the EOF, and
- Two Engineering Support individuals at the TSC.
For example, the two Dose Assessment Supervisor & Analysts at the EOF could either be two individuals qualified to perform the Supervisor/Analyst function or for both positions or one qualified individual to perform the Supervisor Function and another qualified individual to perform the Analyst function. For the Engineering Support positions at the TSC, the NRC staff could not determine whether these were intended to be an electrical and a mechanical engineer or some other type of engineering support.
If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 9
The SNC Supplemental Analysis Table includes wording such as, [t]he Operations STA [Shift Technical Advisor] and [t]he STA and other SROs, which imply that an on-shift individual will be available to perform the STA function. The SNC LAR further provides that this individual would be available to perform engineering activities, such as troubleshooting. Although the LAR implies that an STA will be available, the only reference the NRC staff found regarding an STA in the proposed SNC SEP was a note that stated, [t]he STA is not counted in the total because this position may be performed by qualified on-shift personnel assigned other functions. Provide clarification regarding STA and engineering functions as follows:
- a. Explain how the SNC will consistently ensure that an individual (dedicated STA) will be available in 60 minutes from the declaration of an Alert or greater classification level to evaluate reactor conditions.
- 2. By letter dated August 9, 2018 (ADAMS Accession No. ML18226A094), SNC provided that the TSC Reactor Engineer (STA) performed the following engineering functions:
- Monitoring of critical safety function status trees,
- Verification of safety injection actuation and plant response,
- Tracking of hydrogen concentrations, and
- Oversight of reactor shut down and trip response actions.
Although these engineering functions seem appropriate for an on-shift individual with STA expertise to evaluate reactor conditions, the electrical and mechanical engineers would provide augmentation to the above capability regarding such activities as troubleshooting and providing engineering support to maintenance personnel. Explain how SNC will ensure that electrical and mechanical engineering expertise, provided by personnel who are qualified by site-specific engineering training programs, are available to support troubleshooting and repair activities in 60 minutes from the declaration of an Alert or greater classification level.
RAI 10
The SNC SEP appears to retain a Security Supervisor position, which would also be controlled under the Security Plan, along with a proposed Security Coordinator located at the EOF. Specific responsibilities of the Security Coordinator were not apparent in the SNC SEP. Additionally, no discussion was apparent regarding how any security-related EP functions would be transferred from the Security Supervisor to the Security Coordinator.
Explain what emergency preparedness function is performed by the Security Coordinator. Additionally, please describe how emergency preparedness function(s) is(are) transferred from the on-shift Security Supervisor to the Security Coordinator following augmentation of Alert or greater classification level.
RAI 11
The SNC Supplemental Analysis Table provides that augmenting an OSC Lead Supervisor is not necessary because operators are, or will be, trained on numerous troubleshooting, repair and corrective actions.
The Supplemental Analysis further provides that [m]any of the repair and corrective actions that go beyond the skill of the craft for NLO(s) [non-licensed operators] are more likely significant or complex enough that work sequence planning and tagging would be required. A similar discussion was provided regarding the engineering and maintenance technician augmentation positions.
However, the original basis for the previous approval of the ERO staffing composition and staff augmentation times stated, in part [wording varied in each safety evaluation]:
HNP Emergency Plan, Revision 36, provides for one mechanical journeyman, two electrical journeymen, and one instrument and controls technician on-shift to support the Repair and Corrective Action task. The on-shift maintenance staffing numbers proposed in the HNP SEP Annex will be reduced to one on-shift electrical journeyman. A
maintenance supervisor will be added to the on-shift staffing complement to provide supervisory oversight for repair and corrective actions, further enhancing the on-shift response capability.
Additionally, RIS 2016-10 provides the following considerations for Technical Support to support proposed extension to 90-augmentation times:
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).
- a. Explain how the SNC NLOs be trained and qualified to perform troubleshooting, repair and corrective actions at the same level as maintenance technicians prior to the implementation of the proposed SNC SEP. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution
- b. Explain how the on-shift SNC SROs be trained and qualified at mechanical and electrical engineers in accordance with site-specific engineering training programs. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution
- c. If SNC NLOs and SROs will not be trained as maintenance technicians and engineers, respectively, explain how will SNC ensure that qualified maintenance technicians and engineers provide augmentation within 60 minutes of an Alert or greater classification level. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution
- d. Please explain how SNC will ensure that the proposed ERO organization will provide maintenance and/or engineering support within 60 minutes of an Alert or greater emergency classification. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 12
Based on a review of the SNC LAR, as supplemented, the NRC staff determined that SNC proposes to have a News Writer report to the EOF within 90 minutes. The SNC SEP provides that the News Writer reports to the EOF Manager, gathers information and prepares news bulletins verified for distribution.
Based on a further review of the SNC SEP, it appears that the Public Information Director is the appropriate individual to manage and coordinate media information related to the event. Considering that one of this individuals responsibilities is to manage approval and disseminate news bulletins, it does not appear that the News Writer will not be able to perform their designated function unless the Public Information Director is available. Although the supplement provides that SNC currently uses a Joint Information System approach and will continue to provide media information within 60 minutes of an Alert or greater classification level, the NRC staff could not identify an individual designated to
perform this function in the proposed SNC SEP within 60 minutes of an Alert of higher classification level.
Explain what individual will be available within 60 minutes of the declaration of an Alert or greater classification level to manage and coordinate media information related to the event. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 13
The SNC SEP provides that upon the notification of an Alert or higher classification, the Public Information Director and corporate staff assigned JIC functions assemble at the Corporate Media Center (CMC). Considering that the SNC SEP does not provide augmentation times for the Joint Information Center (JIC) nor does the SNC SEP identify minimum position for the JIC, the NRC staff could not determine who, other than the Public Information Director, was required to assemble at the CMC.
Provide a description of the CMC staffing that would be required to perform the JIC function when media information related to the event is being managed and coordinated from the CMC.
RAI 14
Table B-1 of NUREG 0654 states, IT [information technology] staff is only required to be described in the emergency plan if critical digital assets are identified per 10 CFR 73.54 [Protection of digital computer and communication systems and networks]. The proposed SNC SEP does not appear to describe IT staff.
- a. Does the SNC SEP rely on any critical digital assets identified per 10 CFR 73.54?
- a. If SNC SEP does rely on any critical digital assets identified per 10 CFR 73.54, identify where a description of IT staff, including augmentation timing, is located in the proposed SNC SEP. If the licensee determines that this this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 15
The SNC LAR, as supplemented, provides that the Firefighting, and the Rescue Operations and First Aid Functions are more appropriately addressed in other licensing documents. Please explain what licensing documents address appropriately address the Firefighting, and the Rescue Operations and First Aid Functions. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 16
Although the SNC LAR states, SNC has evaluated each proposed change individually to ensure that key functions and tasks are maintained and there is timely augmentation of response capabilities, relevant details associated with that evaluation were not provided for the areas listed below. The justification for
these changes should provide sufficient detail for the NRC staff to independently determine that the proposed changes are reasonable.
- a. Provide a justification that supports the removal of the following positions from the SNC SEP:
- TSC Support Coordinator,
- TSC Chemistry Support,
- EOF Support Coordinator,
- EOF Administrative Support Staff, and
- JIC Clerical Staff.
- b. Provide a justification that supports elimination of the following as minimum staff positions:
- TSC Manager,
- EOF Manager,
- JIC Manager,
- JIC Facility Coordinator,
- JIC Media Relations Representative,
- JIC Public Response Coordinator, and
- Public Information Director.
RAI 17
The proposed SNC SEP OSC only has the OSC Manager indicated as a minimum staffing position. The SNC SEP provides that the OSC has been established to provide for coordinating and planning activities and staging personnel and equipment. Explain how the OSC can be considered as activated when the only individual required to be present is the OSC Manager. If the licensee determines that this request identifies a concern with the current LAR, then the staff requests the licensee to either propose a change to the LAR or another solution.
RAI 18
The definitions section of the proposed SNC Standard Plan states, in part:
Facility Activation An Emergency Response Facility (ERF) is activated when minimum staff positions as noted in Figures B.2.1.A. B.2.2.A. and B.3.1.A are available, and the facility is ready to assume its assigned functions. Although the facility is activated, the on-shift staff may prioritize completion of critical tasks prior to turnover.
Those ERO positions designated as minimum staffing in the SNC SEP are those required to activate their respective ERF. Specifically, these are the ERO positions that are the minimum
needed to implement the SNC SEP (i.e., if any position or function is not staffed then the Emergency Plan may not be effectively implemented). The planning standard in paragraph 50.47(b)(14) of Title 10 of the Code of Federal Regulations states:
Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
Section N, Exercises and Drills, of the SNC SEP reviewed and approved by the NRC in letter dated March 14, 2017 (ADAMS Accession No. ML16141A090), states SNC-operated nuclear power plants will conduct a biennial exercise and additional periodic drills. An exercise is an event that tests integrated capability, and a major portion of the basic elements of emergency preparedness plans and organizations. Drills and exercises shall:
- Test the adequacy of timing and content of implementing procedures and methods.
- Test emergency equipment and communications networks.
- Test the public notification system.
- Ensure emergency organization personnel are familiar with their duties.
However, this plan does not address whether these periodic drills or exercises will be used on a continuing basis to specifically evaluate the adequacy of the minimum staffing levels to ensure that they continue to retain the necessary key skills to perform required major functions prior to full augmentation.
Describe how SNC plans to specifically evaluate the adequacy of the minimum staffing levels to perform required functions until full augmentation, with the proposed ERO staffing changes to ensure continued effective implementation of the respective emergency plans for each site.
Hearing Identifier: NRR_DRMA Email Number: 837 Mail Envelope Properties (BY5PR09MB56669B6EB6599F6FE5865846FA050)
Subject:
RAIs for SNC Fleet EP LAR (L-2020-LLA-0150 and L-2020-LLA-0151)
Sent Date: 10/14/2020 12:28:50 PM Received Date: 10/14/2020 12:28:50 PM From: Lamb, John Created By: John.Lamb@nrc.gov Recipients:
"Lowery, Ken G." <KGLOWERY@southernco.com>
Tracking Status: None "Joyce, Ryan M." <RMJOYCE@southernco.com>
Tracking Status: None "Enfinger, Timothy Lee" <TLENFING@SOUTHERNCO.COM>
Tracking Status: None Post Office: BY5PR09MB5666.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 35640 10/14/2020 12:28:50 PM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: