Letter Sequence Meeting |
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EPID:L-2022-LLA-0166, Proposed License Amendment Request to Revise Emergency Plan Staff Augmentation Times (Approved, Closed) |
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Category:Meeting Briefing Package/Handouts
MONTHYEARML24029A2362024-01-30030 January 2024 Preliminary Results of the Environmental Review, Subsequent License Renewal ML23338A1522023-12-0707 December 2023 Public Meeting Slides for North Anna and Surry Emergency Plan Augmentation Times License Amendment Request ML23255A0992023-09-15015 September 2023 Slides for September 15, 2023 Public Meeting on Poanhi Seismic Evaluations ML23103A3482023-04-14014 April 2023 Annual Assessment Meeting Presentation for North Anna and Surry ML21221A0332022-06-17017 June 2022 Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - NRC Slides ML22097A2262022-04-13013 April 2022 Presubmittal Presentation April 13, 2022 One-time TS Change of AOT for Unit 2 AFW Piping Replacement ML22055B1132022-03-0202 March 2022 Technical Support Center (TSC) Relocation Proposed License Amendment Request - NRC Pre-Submittal Meeting, March 2, 2022 ML21174A3042021-06-23023 June 2021 SLRA RAI Response Public Meeting - 21-06-24 ML21221A1542021-05-27027 May 2021 Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - Dominion Slides ML21134A1632021-05-20020 May 2021 Resolution of Tornado Wind Nonconformances Proposed License Amendment Request NRC Pre-Submittal Meeting - May 20, 2021 ML21127A1362021-05-13013 May 2021 May 13, 2021 NRC Pre-Submittal Meeting - Surry Power Station New Fuel Storage and Spent Fuel Pool Criticality Analysis Proposed License Amendment Request ML21132A2892021-05-13013 May 2021 SLRA RAI Response Public Meeting ML21145A2172021-05-13013 May 2021 Discussion on May 13, 2021 with Dominion on Select Staff RAIs on North Anna Subsequent License Renewal Application - Dominion Slides ML21034A5972021-02-10010 February 2021 External Presentation Am Atkinson_Nrc ISG-06 Meeting Dominion Digital IC Project 02102021 ML20307A1772020-11-0404 November 2020 NRC Presentation North Anna Power Station, Units 1 and 2 Subsequent License Renewal Review ML20309A5912020-10-14014 October 2020 Pre-Submittal Meeting for License Amendment Requests to Implement Batch Framatome 15 X 15 AGORA-5A-I (Agora) Fuel at Surry Power Station Units 1 and 2 (SPS) - Slides ML20288A3472020-10-14014 October 2020 (COVID-19) Emergency Preparedness Exemption Pre-Application Meeting ML20099F2992020-04-0909 April 2020 NRC Slides for North Anna pre-app April 9 ML20099F2412020-04-0909 April 2020 Co., NRC Safety Pre& 8208;Application Meeting North Anna Power Station (NAPS) ML20098B7292020-04-0707 April 2020 Sur 2019 Annual Assessment Meeting Presentation ML20098B6022020-04-0707 April 2020 Annual Assessment Meeting Presentation ML19297D1872019-11-18018 November 2019 Pre-Application Meeting - Dominion Slides ML19311C5292019-11-0707 November 2019 Dsies Slides for Nov. 7, 2019 Public Meeting ML19007A2162019-01-0808 January 2019 Subsequent License Renewal Environmental Scoping Meeting, Surry Power Station, Unit Nos. 1 and 2, January 8, 2018 ML18320A2502018-11-20020 November 2018 50.90 License Amendment Request - Dominion Fleet EAL Scheme Changes, November 20, 2018 Public Meeting ML18141A3072018-05-21021 May 2018 18 - SLR Status ML18032A5842018-02-0707 February 2018 SLR Pre-Application 02/07/2018 Meeting - Dominion Energy Slides ML17320A2012017-11-15015 November 2017 Modeling FLEX in Surry Power Station Internal Events and Flooding PRA ML17123A2092017-05-0303 May 2017 Summary of Meeting to Discuss Annual Assessment of the North Anna Power Station, Units 1 and 2 with the Public for the Period of January 1, 2016 Through December 31, 2016 ML16320A5232016-09-0707 September 2016 Pre-Submittal Meeting with Surry Power Station Regarding Carbon Fiber Reinforced Polymer Alternative Request ML16124A7592016-05-0303 May 2016 April 12, 2016 Summary of Public Meeting - Surry, Units 1 and 2 ML16124A7582016-05-0303 May 2016 April 14, 2016, Summer of Public Meeting - North Anna, Units 1 and 2 ML16124A7632016-05-0303 May 2016 April 14, 2016, Summary of Public Meeting - North Anna Power Station, Units 1 and 2 ML16104A3822016-04-26026 April 2016 New Fuel Storage Rack & SFP Criticality Analysis for April 26th 2016 Scheduled Category 1, Pre-Submittal Public Teleconference ML16104A3872016-04-13013 April 2016 Criticality Analysis Checklist for North Anna ML15273A4292015-09-29029 September 2015 Revised Slides for September 29, 2015 Meeting with Dominion Re North Anna ISFSI License Renewal ML15153A0452015-05-13013 May 2015 Revised North Anna ISFSI Presentation Slides - TN-32 High Burnup Dry Storage Research Project, May 13, 2015 (Tom Brookmire) ML15133A0822015-05-13013 May 2015 ISFSI Presentation Slides - TN-32 High Burnup Dry Storage Research Project, May 13, 2015 (Tom Brookmire) ML15128A5462015-05-0808 May 2015 Summary of Public Meeting with North Anna, Units 1 and 2 to Discuss the Annual Assessment with the Public ML14176A0922014-06-25025 June 2014 6/25/2014, Dominion Public Meeting Presentation for Surry GMRS Profile ML14101A1132014-04-11011 April 2014 Summary of Meeting with Public to Discuss Annual Assessment of Surry Power Station with the Public for the Period of January 1, 2013 - December 31, 2013 ML14101A1202014-04-11011 April 2014 Public Meeting Summary - North Anna Power Station, Docket Nos. 50-338, 50-339 ML14058B1762014-03-0606 March 2014 Presentation Slides - North Anna ISFSI - High Burnup Dry Storage Confirmatory Data Project, TN-32 Storage Cask, Tom Brookmire, March 6, 2014, Docket No. 72-16, TAC No: L24886 ML14071A1672014-01-28028 January 2014 Enclosure 2: Presentation Slides - North Anna ISFSI TN-32 Cask and Pad 1 Assessments Following August 23, 2011, Central Virginia Earthquake ML13159A0092013-06-0404 June 2013 Notable Failures in Nondustructive Testing - June 4, 2013 Public Meeting ML13151A1022013-05-31031 May 2013 Summary of Public Meeting with Virginia Electric and Power Company, to Discuss Annual Assessment of Surry Power Stationfor the Period of January 1, 2012 December 31, 2012 ML12257A2342012-09-11011 September 2012 5-Hacker - North Anna Mockup and Search Unit Action Presentation Sept 10 ML12257A2002012-09-11011 September 2012 2-North Anna Extent of Condition Presentation 9-7-12 Sept 10 ML12131A5052012-05-0909 May 2012 Presentation for 2011 North Anna EOC Annual Assessment Meeting ML12115A0732012-04-19019 April 2012 RCS Standpipe White Violation Slides 2024-01-30
[Table view] Category:Slides and Viewgraphs
MONTHYEARML24029A2362024-01-30030 January 2024 Preliminary Results of the Environmental Review, Subsequent License Renewal ML23338A1522023-12-0707 December 2023 Public Meeting Slides for North Anna and Surry Emergency Plan Augmentation Times License Amendment Request ML23255A0992023-09-15015 September 2023 Slides for September 15, 2023 Public Meeting on Poanhi Seismic Evaluations ML23103A3482023-04-14014 April 2023 Annual Assessment Meeting Presentation for North Anna and Surry ML21221A0332022-06-17017 June 2022 Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - NRC Slides ML22097A2262022-04-13013 April 2022 Presubmittal Presentation April 13, 2022 One-time TS Change of AOT for Unit 2 AFW Piping Replacement ML22091A0902022-04-0101 April 2022 Combined 2021 Assessment Meeting Slides ML22055B1132022-03-0202 March 2022 Technical Support Center (TSC) Relocation Proposed License Amendment Request - NRC Pre-Submittal Meeting, March 2, 2022 ML21221A1482021-05-27027 May 2021 Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - NRC Slides ML21221A1542021-05-27027 May 2021 Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - Dominion Slides ML21134A1632021-05-20020 May 2021 Resolution of Tornado Wind Nonconformances Proposed License Amendment Request NRC Pre-Submittal Meeting - May 20, 2021 ML21145A2172021-05-13013 May 2021 Discussion on May 13, 2021 with Dominion on Select Staff RAIs on North Anna Subsequent License Renewal Application - Dominion Slides ML21132A2892021-05-13013 May 2021 SLRA RAI Response Public Meeting ML21127A1362021-05-13013 May 2021 May 13, 2021 NRC Pre-Submittal Meeting - Surry Power Station New Fuel Storage and Spent Fuel Pool Criticality Analysis Proposed License Amendment Request ML21034A5972021-02-10010 February 2021 External Presentation Am Atkinson_Nrc ISG-06 Meeting Dominion Digital IC Project 02102021 ML20307A1772020-11-0404 November 2020 NRC Presentation North Anna Power Station, Units 1 and 2 Subsequent License Renewal Review ML20288A3472020-10-14014 October 2020 (COVID-19) Emergency Preparedness Exemption Pre-Application Meeting ML20309A5912020-10-14014 October 2020 Pre-Submittal Meeting for License Amendment Requests to Implement Batch Framatome 15 X 15 AGORA-5A-I (Agora) Fuel at Surry Power Station Units 1 and 2 (SPS) - Slides ML20099F2412020-04-0909 April 2020 Co., NRC Safety Pre& 8208;Application Meeting North Anna Power Station (NAPS) ML20099F2992020-04-0909 April 2020 NRC Slides for North Anna pre-app April 9 ML20098B6022020-04-0707 April 2020 Annual Assessment Meeting Presentation ML20098B7292020-04-0707 April 2020 Sur 2019 Annual Assessment Meeting Presentation ML19297D1872019-11-18018 November 2019 Pre-Application Meeting - Dominion Slides ML19311C5292019-11-0707 November 2019 Dsies Slides for Nov. 7, 2019 Public Meeting ML19296D7862019-11-0606 November 2019 Dseis Slides for November 7, 2019 Public Meeting ML19248C7352019-09-0909 September 2019 CFR 50.69 License Amendment Request Pre-Submittal Meeting with NRC - September 9, 2019 ML19007A2162019-01-0808 January 2019 Subsequent License Renewal Environmental Scoping Meeting, Surry Power Station, Unit Nos. 1 and 2, January 8, 2018 ML18141A3072018-05-21021 May 2018 18 - SLR Status ML18102A5692018-04-17017 April 2018 Dominion'S Presentation on Surry'S SLRA Safety Meeting-Final (for April 17, 2018) ML18086A7742018-02-21021 February 2018 LOR Program Biennial Inspection 71111.11B Exam Overlap Issues ML18032A5842018-02-0707 February 2018 SLR Pre-Application 02/07/2018 Meeting - Dominion Energy Slides ML17320A2012017-11-15015 November 2017 Modeling FLEX in Surry Power Station Internal Events and Flooding PRA ML16124A7592016-05-0303 May 2016 April 12, 2016 Summary of Public Meeting - Surry, Units 1 and 2 ML16124A7632016-05-0303 May 2016 April 14, 2016, Summary of Public Meeting - North Anna Power Station, Units 1 and 2 ML16124A7582016-05-0303 May 2016 April 14, 2016, Summer of Public Meeting - North Anna, Units 1 and 2 ML15273A4292015-09-29029 September 2015 Revised Slides for September 29, 2015 Meeting with Dominion Re North Anna ISFSI License Renewal ML15153A0452015-05-13013 May 2015 Revised North Anna ISFSI Presentation Slides - TN-32 High Burnup Dry Storage Research Project, May 13, 2015 (Tom Brookmire) ML15133A0822015-05-13013 May 2015 ISFSI Presentation Slides - TN-32 High Burnup Dry Storage Research Project, May 13, 2015 (Tom Brookmire) ML15128A5462015-05-0808 May 2015 Summary of Public Meeting with North Anna, Units 1 and 2 to Discuss the Annual Assessment with the Public ML14176A0922014-06-25025 June 2014 6/25/2014, Dominion Public Meeting Presentation for Surry GMRS Profile ML14058B1762014-03-0606 March 2014 Presentation Slides - North Anna ISFSI - High Burnup Dry Storage Confirmatory Data Project, TN-32 Storage Cask, Tom Brookmire, March 6, 2014, Docket No. 72-16, TAC No: L24886 ML14071A1672014-01-28028 January 2014 Enclosure 2: Presentation Slides - North Anna ISFSI TN-32 Cask and Pad 1 Assessments Following August 23, 2011, Central Virginia Earthquake ML13159A0092013-06-0404 June 2013 Notable Failures in Nondustructive Testing - June 4, 2013 Public Meeting ML13151A1022013-05-31031 May 2013 Summary of Public Meeting with Virginia Electric and Power Company, to Discuss Annual Assessment of Surry Power Stationfor the Period of January 1, 2012 December 31, 2012 ML12257A2002012-09-11011 September 2012 2-North Anna Extent of Condition Presentation 9-7-12 Sept 10 ML12257A2342012-09-11011 September 2012 5-Hacker - North Anna Mockup and Search Unit Action Presentation Sept 10 ML12131A5052012-05-0909 May 2012 Presentation for 2011 North Anna EOC Annual Assessment Meeting ML12129A2532012-05-0808 May 2012 EOC Poster Boards 2011 ML12115A0732012-04-19019 April 2012 RCS Standpipe White Violation Slides ML11305A0452011-11-0101 November 2011 Region II - North Anna Public Meeting Slides 2024-01-30
[Table view] |
Text
North Anna And Surry Emergency Plan Staffing Amendment Michael Norris, SR. EP Specialist Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 1
Agenda
Background
- Nov 7, 2022 - LAR Submitted
- Mar 30, 2023 - RAI Response
- May 25, 2023 - Public Meeting
- July 10, 2023 - Regulatory Audit
- Oct 12, 2023 - Second RAI Response
- Two Outstanding Review Issues
Emergency Response Organization (ERO) Guidance
- 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]
[ADAMS Accession No. ML19347D139]
4
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.
5
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 (e.g., NUREG/CR-7190).
- Studies also show that leadership is crucial to effective and safe team performance.
6
Dominion Request
- During normal plant operations, the Shift Manager (SM) is responsible for the control room command function. Unit Supervisors assume control room command functions during abnormal and emergency conditions.
Once an emergency is declared at either NAPS or SPS, the respective SM performs the Station Emergency Manager (SEM) role as a dedicated resource responsible for classification and site oversight-and-control functions associated with event response.
- Because the Unit Supervisors perform the control room command function for plant operations and the SM is relieved of the control room command function during abnormal and emergency conditions, relief of SM duties within the 60-minute criteria is met. Therefore, separation of Control Room and EP oversight functions allows the SEM to perform both event classification and oversight of event response for the first 90-minutes.
7
Dominion Proposed Emergency Plan Shift Manager Responsibilities
- 1) Classifying the emergency,
- 2) Authorizing notification to the NRC, State and local agencies of the emergency status,
- 3) Recommending protective measures,
- 4) Authorizing emergency exposure limits,
- 5) Activating emergency personnel and facilities,
- 6) Reducing power or shutting down both reactors,
- 7) Committing company funds as necessary,
- 8) Acquiring emergency equipment or supplies,
- 9) Ordering site evacuation,
- 10) Restricting access to the site,
- 11) Notifying company management,
- 12) Implementing work schedules, and
- 13) Directing onsite emergency activities.
8
NRC Guidance RIS 2006-10 guidance for 60-Minute ERO Augmentation Times to 90 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). 9
NRC Guidance The technical basis for the revised Table B-1 This function is important for effective emergency response because adequate command and control enables a licensee to effectively develop priorities for response planning and corrective action(s) and to provide a unified approach to the event response by providing a single individual with overall command and control authority.
This function is also consistent with the Incident Command portion of the National Incident Management System (NIMS), dated December 2008. It should be staffed and maintained at all times. This function is typically assigned to the Operations Shift Manager (OSM). The augmentation (relief) of this position is intended to relieve the OSM of EP functions so that the OSM can focus on the event response from an operations perspective.
10
Conclusion LAR has not provided information sufficient for the NRC to justify the proposed extension in the amount of time an individual capable of relieving the shift manager of either the shift manager or emergency director responsibilities from 60 minutes to 90 minutes.
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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.
12
Dominion Response Dominion proposes to use a performance-based approach to justify the alternative means of compliance. This approach utilizes a layered methodology which consists of evaluation of both design basis and beyond design basis events through:
- The procedure-based analysis (hereafter referred to as the analysis) that considers actions which justify deviations from the designated staffing levels in NUREG-0654, Rev 2, Table B-1, and
- The revised assumptions included in NUREG/CR-7110, Vol 2, Revision 1, State of-the-Art Reactor Consequence Analysis Project (SOARCA) Surry Integrated Analysis, August 2013, as the justification for a 90-minute augmented response for maintenance personnel.
. 13
NRC Guidance RIS 2006-10 guidance for 60-Minute ERO Augmentation Times to 90 Minutes Repair and Corrective Actions To adequately support an extension of the response time for these responders, the licensee should demonstrate that the responsibilities of these positions can be covered with on-shift staff or earlier responders.
14
NRC Guidance The technical basis for the revised Table B-1 From an EP perspective, the ability to get emergency core cooling system (ECCS) equipment operational was the primary basis for necessitating maintenance expertise while on-shift. Maintenance staff expertise may be advantageous for licensees to consider for other reasons, and at their discretion; however, for the purposes of NUREG-0654/FEMA-REP-1, the only area where maintenance availability should typically be necessary on-shift is for ECCS issues. However, a licensees ECCS is designed to be redundant and diverse such that common mode failures are very unlikely. As a result, the need to accommodate maintenance functionality on-shift is unnecessary. Nevertheless, a minimum number of maintenance personnel should respond to an event as part of the ERO, with more personnel available on an as-needed basis depending on the event. The augmentation (support) of the electrician and mechanic positions should occur within 60-minutes of an Alert ECL, (or greater), and is typically staffed in the OSC.
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NUREG-0654, Table B-1, Revision 2 Considerations Conclusion LAR has not provided information sufficient for the NRC to justify the proposed extension in timing of augmenting electrical and maintenance technicians from 60 minutes to 90 minutes.
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Path Forward
- Currently NRC staff does not see sufficient justification for the discussed issues
- For ERO staffing, LAR needs to identify appropriate relief the Shift Manager at 60 minutes
- For repair team staffing, a significant amount of technical analysis and detail would be required to justify the acceptability of this change 17