ML21208A021

Wp on Erfer PI (to NRC) Rev July 21

ML21208A021
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/27/2021
From:	Slider J Nuclear Energy Institute
To:
Quinones-Navarro J
References
Download: ML21208A021 (5)

Text

NEI Reactor Oversight Process Task Force Whitepaper -

Proposal to Replace the ANS PI with an ERFER PI Introduction This Reactor Oversight Process (ROP) Whitepaper proposes to replace the Alert and Notification System (ANS) performance indicator (PI) with an Emergency Response Facility and Equipment Readiness (ERFER) PI. The proposed change is driven by the growing number of sites replacing their offsite siren system with the Integrated Public Alert and Warning System (IPAWS)1 as the primary method to accomplish prompt public alerting during a radiological emergency. If adopted, this change would affect the guidance in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and the PI databases maintained by the U.S. Nuclear Regulatory Commission (NRC) and the Institute of Nuclear Power Operations (INPO).

NEI 99-02 Section Affected The change proposed by this whitepaper affects the entirety of the NEI 99-02 section entitled, Alert and Notification System Reliability, which is presented on pages 60 through 64 of Revision 7.2 The guidance in this section would be replaced with the guidance shown below, under Proposed Changes to NEI 99-02. The associated elements in the NRC and INPO PI databases would also need to be changed such that licensees could report data for the new ERFER PI.

Discussion Until recently, each nuclear power plant licensee had provisions to collect and report data for the ANS PI described in NEI 99-02. This indicator monitors the reliability of the offsite ANS, a critical link for alerting and notifying the public of the need to take protective actions. It provides the percentage of the sirens that are capable of performing their safety function based on regularly scheduled tests; however, sites have begun replacing offsite siren systems with the IPAWS as the primary method to accomplish prompt public alerting during a radiological emergency. For a site that has replaced an offsite siren system with IPAWS, the ANS PI is moot for performance assessment purposes (i.e., there is no data to report).

Looking further back, the NRC staff addressed the topic of replacing the ANS PI with an emergency response facility (ERF) readiness PI in Enclosure 5, Emergency Preparedness Area,3 of SECY-19-0067, Recommendations for Enhancing the Reactor Oversight Process,4 dated June 28, 2019. In addition to eliminating the impact from IPAWS adoption, the staff noted that replacing the ANS PI with an ERF readiness PI would permit licensees to utilize the ROP EP PIs to satisfy the requirements of 10 CFR 50.54(t)(1)(ii) to extend the 12-month review frequency to 1

Information about IPAWS can be found here.

2 Refer to ADAMS Accession Number ML13261A116.

3 Refer to ADAMS Accession Number ML19070A045.

4 Refer to ADAMS Accession Number ML19070A050.

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NEI Reactor Oversight Process Task Force Whitepaper -

Proposal to Replace the ANS PI with an ERFER PI a 24-month review frequency of a licensees EP program. The Commission has not yet voted on SECY-19-0067.

Because several sites have recently transitioned their primary prompt public alerting method from offsite sirens to IPAWS, the NRC and INPO are currently exploring data-entry work-arounds for sites that are not reporting ANS PI data. The work-arounds are needed to enable the INPO PI data collection system (IRIS) to produce a PI data file the NRCs data system can accept when the ANS PI data is not reported. NEI believes that the resources necessary to make the changes at NRC and INPO could be better used by modifying the data systems to support the use of the ERFER PI.

Given the events discussed above, the NRC staff has suggested that it may be appropriate to seek Commission approval on the narrow question of moving forward with an ERFER PI to replace the ANS PI. NEI supports that approach.

Proposed Change to NEI 99-02 The proposed change to NEI 99-02 is presented below, beginning on the next page; this guidance would replace the existing ANS PI guidance.

The approach used for ROP ERFER PI is the same as that used for the ERFER PI described in the NRC-endorsed NEI White Paper, Implementing a 24-Month Frequency for Emergency Preparedness Program Reviews.5 As stated in of SECY-19-0067, this makes Efficient use of the ROP (as revised) to extend the review frequency in Title 10 of the Code of Federal Regulations (10 CFR) 50.54(t) from 12 months to 24 months. Both PIs are focused on the out-of-service time for emergency response facilities and equipment needed by a licensee to perform Risk Significant Planning Standard (RSPS) functions, and whether a compensatory measure was implemented. The selected out-of-service times are appropriate for the intended use of each PI:

• 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for requiring an accelerated independent EP program review

• 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> for an ERFER PI White status To promote understanding of the relationship between the ROP ERFER PI and the NEI White Paper ERFER PI, it is proposed to include text in the Clarifying Notes section of the ROP ERFER PI specifically indicating that use of the ROP ERFER PI with a different out-of-service time - 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instead of 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> - would permit a licensee to utilize the ROP ERFER PI to satisfy the requirements of 10 CFR 50.54(t)(1)(ii). The 24-hour threshold is contained in the ERFER PI described in the NEI White Paper. It should be noted that the White Paper already addresses the use of the ROP Drill and Exercise Performance (DEP) indicator and the Emergency Response Organization (ERO) PI as indicators to support the implementation of a 24-month review frequency.

5 Refer to ADAMS Accession Number ML19344C419.

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NEI Reactor Oversight Process Task Force Whitepaper -

Proposal to Replace the ANS PI with an ERFER PI The threshold for the ROP ERFER PI was set at 1 per quarter based on professional judgment that the inability to perform an RSPS function for greater than 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> represents performance outside an expected range of nominal utility performance.

The anticipated path forward to implementation of the ERFER PI includes these actions:

(1) Gain alignment between the industry and the NRC on the ERFER PI described in this ROP White Paper.

(2) NEI to submit a ROP whitepaper/FAQ to formally seek the necessary change to NEI 99-02.

(3) Public meeting engagement to agree on the resolution of the ROP whitepaper/FAQ, including an implementation schedule; and (4) NRC and INPO to modify their data systems to accommodate the new ERFER PI.

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NEI Reactor Oversight Process Task Force Whitepaper -

Proposal to Replace the ANS PI with an ERFER PI Emergency Response Facility and Equipment Readiness Purpose The Emergency Response Facility and Equipment Readiness (ERFER) indicator measures licensee performance in maintaining the emergency response facilities and equipment of greater importance to the protection of public health and safety.

Indicator Definition The number of occurrences during a quarter that a Risk Significant Planning Standard (RSPS) function could not be performed for greater than 168 continuous hours due to an issue with an emergency response facility or piece of emergency response equipment.

Data Reporting Elements The number of occurrences that an issue with an emergency response facility or piece of emergency response equipment prevented the performance of an RSPS function for greater than 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> continuous hours and no Compensatory Measure was implemented.

Calculation The site value for this indicator is calculated as follows:

Count the number occurrences where: (See Clarifying Notes below.)

1. An issue with an emergency response facility or piece of emergency response equipment prevented the performance of an RSPS function, AND

2. The period during which the issue existed was greater than 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> from the Time of Discovery, AND

3. A Compensatory Measure was not implemented during the 168-hour period.

Definition of Terms The definition of the terms Risk Significant Planning Standard function, Time of Discovery, and Compensatory Measure are those described in NRC Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process.6 Clarifying Notes The ERFER indicator reflects the ability of a licensee to perform the surveillance, testing, inventory, and preventative and corrective maintenance activities that contribute to the availability of the facilities and equipment necessary to accomplish RSPS functions.

6 See Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, Issue Date September 22, 2015, (ADAMS ML15128A462), Section 2.0, Definitions, Abbreviations, and Acronyms.

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NEI Reactor Oversight Process Task Force Whitepaper -

Proposal to Replace the ANS PI with an ERFER PI Consistent with the Indicator Definition, a facility or equipment issue must be impactful enough to prevent the performance of an RSPS function (e.g., an action necessary to implement an RSPS function cannot be performed); a degraded capability to perform a function should not be counted. A Compensatory Measure need not meet the same design or operating requirements as the methods normally used to perform an RSPS function or response action; however, its effectiveness should be sufficient to ensure that the supported function or action would be accomplished during an actual emergency, albeit in a possibly degraded manner.

To be counted towards the performance indicator, the occurrence of a given facility or equipment issue must exceed 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> during one continuous period (i.e., continuous hours) in one quarter.

The starting point of the issue should be determined in accordance with the Time of Discovery guidance in NRC Inspection Manual Chapter 0609, Appendix B. Further, if an equipment issue affects performance of an RSPS function or response action at multiple facilities (e.g., loss of common computer or communications system) but the impact started at different times depending on the facility, then the performance indicator assessment should use the longest out-of-service time.

If the licensee reports a lost RSPS function or response action under this performance indicator but later determines that the capability was not lost (e.g., through a subsequent engineering analysis), then the performance indicator data should be revised accordingly.

NOTE: At a licensees discretion, the ERFER PI described in this section may be used as a PI to satisfy the requirements of 10 CFR 50.54(t)(1)(ii) to extend the 12-month review frequency of a licensees EP program to 24-months. To do this, the licensee would:

• Substitute/replace the ERFER PI described in NEI White Paper, Implementing a 24-Month Frequency for Emergency Preparedness Program Reviews, dated November 2019 (ML19344C419) with the ERFER PI described in this section, AND

• Change the out-of-service time of the PI being used to satisfy the requirements of 10 CFR 50.54(t)(1)(ii) from 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (i.e., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is for the 10 CFR 50.54(t)(1)(ii)

PI only). The out-of-service time of the ROP ERFER PI remains 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />.

Data Example Threshold

• White 1/quarter

• Yellow N/A

• Red N/A Page 5 of 5 20210721