ML20293A453
| ML20293A453 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/2019 |
| From: | Raymond Hoffman NRC/NSIR/DPR/RLB |
| To: | |
| Raymond Hoffman | |
| References | |
| Download: ML20293A453 (16) | |
Text
U.S. NRC Guidance Related to Emergency Plan Staffing Changes NEI Security and Emergency Preparedness Summit August 19-22, 2019 Raymond J. Hoffman, EP Specialist Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 1
ERO Staffing / Augmentation
- RIS 2016-10, License Amendment Requests for Changes to ERO Staffing and Augmentation
[ADAMS Accession No. ML16124A002]
Clarifies use of NEI 10-05 (On-Shift Staffing Analysis)
Staff evaluation against Table B-1 (NUREG-0654, Revision 1)
- Revised NUREG-0654 Table B-1 / Technical Basis Issues by letter dated June 12, 2018, Alternative Guidance for Licensee EROs
[ADAMS Accession Nos. ML18022A352 / ML16117A427]
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ERO Staffing / Augmentation
- Table B-1 (functions/augmentation times) is intended to provide a model to consider in developing a site-specific emergency plan.
- Emergency plan should describe the minimum ERO staffing plan Supporting EPIPs can describe any other staff response desired, as long as this staff is not critical to effective emergency plan implementation.
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ERO Staffing / Augmentation
- Appendix A to Part 50, General Design Criteria for Nuclear Power Plants, requires that the facility can be operated without undue risk to the health and safety of the public.
- Current emergency operating procedures (EOPs) provide the operator with direction to mitigate the consequences of a broad range of accidents with multiple equipment failures.
- As such, events on a trajectory to exceed EPA PAGs would reasonably be beyond both a nuclear power plants design basis and their site-specific EOPs.
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ERO Staffing / Augmentation
- When evaluating a license amendment request regarding ERO Staffing / Augmentation, the NRC staff considers the following when evaluating changes to the ERO.
- For about the first 45 minutes following an event, the event response will be primarily driven by EOP implementation
- At approximately 60 minutes following an event, either the EOPs were successful in restoring the critical safety functions or either plant equipment is not responding as designed or the event is beyond the design of plant equipment.
- If plant equipment is not responding as designed or if the event is beyond the design of plant equipment at 60 minutes, then maintenance, engineering, or both are required.
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NUREG-0654, Table B-1, Revision 2 Considerations Command and Control Function Performed by the Shift Manager for the first 60 minutes following the declaration of an Alert or higher classification level.
- As time progresses after declaration, so does the workload of the on-shift emergency director.
- Studies show when a large number of tasks are required to be performed in parallel an operator may adopt a strategy of ignoring tasks that appear to be not critical at the moment.
- Studies also show that leadership is crucial to effective and safe team performance.
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NUREG-0654, Table B-1, Revision 2 Considerations Communication Function
- An on-shift communicator will be assigned to perform the function for the first 60 minutes.
The communicator must be able to perform the Communication Function at any time as required. Any other functions assigned the communicator must be able to be deferred whenever communications are required.
- On-shift staffing to be augmented within 60 minutes by:
one dedicated NRC communicator, and one dedicated ORO communicator is required.
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NUREG-0654, Table B-1, Revision 2 Considerations Radiation Protection Function
- Considering that an Alert or higher classification level refers to a radiological event, which could involve radiation levels that are either unknown, elevated or changing, qualified radiation protection (RP) technicians are essential to perform this function.
- RP supervision will initially be performed by the Shift Manager and with augmented by one RP supervisor at the TSC within 60 minutes of an Alert or higher classification level and an additional RP supervisor within 60 minutes of a Site Area Emergency or higher classification level.
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NUREG-0654, Table B-1, Revision 2 Considerations Dose Assessment Function
- A dose assessor will be assigned to perform the Dose Assessment function for the first 60 minutes following an event.
Any other functions assigned the dose assessor must not interfere with the performance of the dose assessment function.
- Dose assessment will be performed by one dose assessor at the TSC within 60 minutes of an Alert or higher classification level and an additional dose assessor within 60 minutes of a Site Area Emergency or higher classification level.
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NUREG-0654, Table B-1, Revision 2 Considerations Engineering Function
- A core/thermal hydraulics engineer will be assigned to perform the Engineering function for the first 60 minutes following an event.
The on-shift core/thermal hydraulics engineer is typically the shift technical advisor (STA), who may also function as the on-shift emergency classification advisor.
The STA may, or may not, be qualified to perform one or more of the TSC Core/Thermal, Electrical, or Mechanical Engineering functions.
- One electrical/I&C, one mechanical, and one core/thermal hydraulics engineer are required to provide augmentation within 60 minutes of an Alert or higher classification level.
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NUREG-0654, Table B-1, Revision 2 Considerations Repair Team Activities Function
- One electrician and one mechanic are required to provide augmentation within 60 minutes and an I&C technician providing augmentation within 90 minutes of an Alert or higher classification level.
Even if the above maintenance personnel cannot promptly restore the ECCS function, they will begin the maintenance process by gathering appropriate information to support prompt troubleshooting or repair.
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NUREG-0654, Table B-1, Revision 2 Considerations Supervision of Repair Team Activities Function
- A Lead OSC supervisor provides augmentation within 60 minutes of an Alert or higher classification level.
- Electrical, Mechanical, I&C, and Radiation Protection Supervisors provide augmentation at the OSC within 90 minutes of an Alert or higher classification level.
The I&C Supervisor responsibility may be combined with the Electrical Supervisor.
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NUREG-0654, Table B-1, Revision 2 Considerations What about FLEX Capability?
Although FLEX equipment is intended to restore or maintain various safety functions during beyond design basis external events, the safety benefit of mitigating strategies provided by FLEX equipment may be used in Risk-Informed Decision Making. Although not explicitly stated in NEI 16-06, Crediting Mitigating Strategies in Risk-Informed Decision Making, (RIDM) a similar approach to crediting mitigating strategies for RIDM could be used for Emergency Preparedness.
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NUREG-0654, Table B-1, Revision 2 Considerations Key highlights for applying a RIDM approach to EP:
- Determine if FLEX equipment could be credited to restore or maintain various safety functions.
- Determine if the availability and reliability of the FLEX equipment is appropriate to credit the equipment for emergency preparedness.
- Determine if the on-shift and ERO staffing at 60 minutes can locate and transport the needed FLEX equipment.
- Determine if the on-shift and ERO staffing at 60 minutes have the procedures to operate the needed FLEX equipment.
- Determine if the on-shift and ERO staffing at 60 minutes have the training to operate the needed FLEX equipment.
- Usage of FLEX equipment for emergency preparedness will be evaluated on a case-by-case basis.
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NUREG-0654, Table B-1, Revision 2 Considerations
- NSIR staff strongly recommends pre-submittal calls early in the LAR development process.
This is especially true if the proposed LAR will include requests that are not directly supported by either guidance or precedence.
- Pre-submittal calls / meetings need to be coordinated through respective NRR/DORL Project Manager.
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For More Information Joseph D. Anderson, Chief Reactor Licensing Branch (301) 287-9300 joseph.anderson@nrc.gov Michael Norris, Sr EP Specialist Reactor Licensing Branch (301) 287-3754 michael.norris@nrc.gov Ray Hoffman, EP Specialist New Reactor Licensing (301) 287-3764 raymond.hoffman@nrc.gov 16 12