NL-15-1392, Enclosure 13 - Vogtle (Units 3 and 4) Staffing - Detailed Description and Technical Evaluation
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Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2;Edwin I. Hatch Nuclear Plant Units I and 2;Vogtle Electric Generating Plant Units I and 2;Vogtle Electric Generating Plant Units 3 and 4 Enclosure 13 Vogtle (Units 3 and 4) Staffing -Detailed Description and Technical Evaluation This enclosure contains 19 pages.
Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation This License Amendment Request (LAR) revises the current on-shift and augmented Emergency Response Organization (ERO) for Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Emergency Plan to incorporate a standard on-shift and augmented ERO staffing plan for the Southern Nuclear Operating Company (SNC) Fleet. This proposed change to the ERO will result in an SNC Fleet standard definition of ERO augmentation time as well as an SNC Fleet standard complement of emergency response positions, titles, duties, and responsibilities.
EP Functions Impacted by the Proposed Change The proposed change impacts the ERO as outlined in 10 CFR 50.47(b) Planning Standards 1 and 2. This change addresses the following Planning Standard Functions:
- 10 CFR 50.47(b) (1): The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the Emergency Plan.* 10 CFR 50.47(b) (2): Process for timely augmentation of on-shift staff is established and maintained.
The proposed change has been reviewed and continues to perform the functions required of 10.CFR 50.47(b) and the related requirements of 10 CFR 50 Appendix E.Emergency Response Organization (ERO) Activation VEGP Unit 3 and Unit 4 Emergency Plan Revision 3.0 requires staffing of augmented ERO at the Alert or higher classification.
Specifically, it states the Emergency Response Facilities (ERFs) "...will be activated and will be operational within about an hour of the initial notification
.... " It also states "SNO's goal is to begin notification of all required on-call Emergency Response Organization (ERO) personnel as soon as practicable, within 15 minutes, following the declaration of an Alert emergency or higher emergency classification at any SNO site." The proposed SNO Fleet standard definition for ERO augmentation is 75 minutes from declaration.
This proposed change redefines the SNO Fleet augmentation time without extension, since the 15 minute notification period will be incorporated in the overall definition of augmentation time. The proposed SNC Fleet definition also removes ambiguous wording such as "about" in order to clearly define the augmentation requirement.
Assignment of Responsibility/Organizational Control VEGP Unit 3 and Unit 4, Emergency Plan Revision 3 identifies the on-shift organization authority and responsibilities for emergency response and assigns major functional areas to on-site and offsite response facilities for augmented response.
In the following analysis, the impact of consolidating ERO positions and reassigning responsibilities is assessed based on the capacity of on-shift staff to perform major tasks for each major functional area of VEGP.Plant Operations and Assessment of Operational Aspects NUREG-0654/FEMA REP-O1 Revision 1 guidance assumes the on-shift staff will provide the Plant Operations and Assessment of Operational Aspects functions throughout the emergency.
The on-shift operations staffing as provided in the current plan Revision 3.0 meets the operations staffing requirements of.10 CFR 50.54(m)(2)(i) and the VEGP Unit 3 and Unit 4 Technical Specifications.
In addition to these requirements, the proposed SNC Fleet El13-1 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation Emergency Plan Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 staffing provides for a dedicated Shift Manager position in the VEGP Unit 3 control room and the VEGP Unit 4 control room. The NUREG-0654/FEMA REP-O1 Revision 1 function of Emergency Direction and Control will be assigned to the Shift Manager on which the emergency event has been declared.Per NUREG-0654/FEMA REP-01 Revision 1, this function may be performed as a collateral duty of one of the individuals also performing the Plant Operations and Assessment of Operational Aspects function.
However, providing a Shift Manager to fill this function as a standalone position enhances the ability of the VEGP Unit 3 and Unit 4 control room staff to fulfill the Plant Operations and Assessment of Operational Aspects function while the dedicated ED addresses aspects of the Emergency Direction and Control function.
This has been demonstrated and documented by performing a 10 CFR Part 50, Appendix E shift staffing evaluation.
In accordance with the current and proposed Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Emergency Plan, the on-shift staffing exceeds the requirements of NUREG-0654/FEMA REP-01 Revision 1 Table B-I. The on-shift staff as described serves to ensure prompt response to emergency events and the capability of on-shift personnel to support plant ,operations or the assessment of operational aspects at the start of an event and until the on-shift staff is properly augmented.
Emergency Direction and Control NUREG-0654/FEMA REP-01 Revision 1 guidance provides that the Emergency Direction and Control function may be fulfilled by personnel assigned other functions.
Per Revision 3.0 of the VEGP Unit 3 and Unit 4 Emergency Plan, the Emergency Director (ED) function is a collateral duty of an ED-qualified individual assigned to the Plant Operations and Assessment of Operational Aspects function until relieved by an augmented ED in the Technical Support Center (TSC) within about one hour of notification of an emergency.
The proposed SNC Fleet Emergency Plan Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 staffing provides for a dedicated Shift Manager position in the VEGP Unit 3 control room and the VEGP Unit 4 control room. The Emergency Direction and Control function will be assigned to the Shift Manager on which the emergency event has been declared.As provided in the current revision to the VEGP Unit 3 and Unit 4 Emergency Plan, the Shift Manager is designated as the on-shift ED to fulfill the function of Emergency Direction and Control until relieved by the Technical Support Center (TSC) ED within about one hour of notification of an Alert or higher emergency.
With the proposed changes, the Shift Manager/ED is relieved within 75 minutes of declaration of an Alert or higher emergency by the ED in the TSC, who then assumes overall control of the response efforts. This remains unchanged in the proposed SNC Fleet Emergency Plan with the exception of redefining the augmentation time to include the time provided for notification of the ERO.In addition to the augmentation of an ED in the TSC within 75 minutes of an Alert or higher declaration, the proposed SNC Fleet Emergency Plan provides an additional ED will be augmented in the Emergency Operations Facility (EOF) within 75 minutes of an Alert or higher declaration.
The aspects of the Emergency Direction and Control function assigned to the TSC and EOF EDs are clearly defined in the proposed SNC Fleet Emergency Plan. The primary role of the EOF ED will be to assume the responsibility for state and local notifications and to approve Protective Action Recommendations (PARs). This ensures that in the unlikely event of a Hostile Action Based (HAB) event in which the site is not accessible to the ERO, an ED would be available in the EOF within 75 minutes of an Alert or higher declaration to assume these aspects of the Emergency Direction and Control function and minimize the burden on the Shift Manager/ED.
E13-2 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation There would be no undue burden on the Control Room staff or impact on the notification function from an addition of the EOF ED. (See table below.)CONTROL ROOM TSC EOF Shift Manager / Emergqency TSC Emergqency Director EOF Emergency Director Director Classification Classification Notifications
- Notifications PARS Emergency Exposure Exposure Controls Controls Technical Support Center (TSC) and Emergency Operations Facility (EOF) positions, which support activation of the Technical Support Center (TSC) and Emergency Operations Facility (EOF), within 75 minutes of event classification:
- TSC Health Physics Network (HPN) Communicator
- EOF Emergency Communications Coordinator
- EOF Security Coordinator
- EOF Offsite Response Coordinator
- EOF Nuclear Spokesperson
- EOF Dose Assessment Supervisor
- EOF Dose Analyst* EOF Technical Supervisor E13-3 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation Notification and Communication NUREG-0654/FEMA REP-01 Revision 1 guidance requires one Communicator to be assigned on-shift.
Revision 3.0 of the VEGP Unit 3 and Unit 4 Emergency Plan provides for two Communicators.
In the proposed SNC Fleet Emergency Plan, the VEGP Unit 3 and Unit 4 staffing for this position is reduced to a single on-shift communicator as provided in NUREG-0654/FEMA REP-01 Revision 1 guidance.
However, this is a dedicated position, which will ensure the Communications function is assigned to an individual with no collateral tasks. A detailed on-shift staffing analysis has been performed in accordance with 10 CER 50 Appendix E that demonstrates the ability of the proposed staffing to perform the Communicator function with no undue burden on the control room staff or impact on the notification function.In addition, the proposed SNC Fleet Emergency Plan provides for the transfer of state and local notifications, including authority to approve the content of the notification form, directly to the EOF from the control room. The proposed change includes both sufficient communications personnel to perform the communications and an ED with the authority to approve the content of the notification.
This ensures that in the unlikely event of a HAB event in which the site is ndt accessible to the ERO, sufficient personnel will be available in the EQE within 75 minutes from time of 'declaration of an Alert or higher emergency classification to assume the Communications function and minimize the burden on the Shift Manager/ED.
The ability to transfer the Communications function directly to the EQE, and provision of sufficient augmented personnel in the EOF to perform the Communicator function within 75 minutes, ensure no additional burden is incurred by the on-shift staff.Radiological Accident Assessment and Chemistry/Radio-Chemistry The function of on-site radiological assessment is: to review radiological conditions on site using data from available instrumentation, assess the impact of changing radiological conditions on emergency classification, assist in accident assessment based upon those changing radiological conditions, and recommend appropriate on-site protective measures.Classification is performed by the Shift Manager/ED using NMP-EP-1 10, Emergency Classification Determination and Initial Action procedure, which uses readily available and easily recognized plant instrumentation to determine the appropriate emergency classification.
Off-site and on-site surveys provide additional information, such as direct radiation measurements, that could be directly applied to emergency classification.
The on-shift Radiation Protection (RP)Technician takes direction from the Control Room to provide radiological assessment support until the OSC is activated.
As part of the Plant Operations and Assessment of Operational Aspects function, the operating crew uses symptom-based emergency operating procedures (EOPs) which minimize the need for specific accident assessment.
The operating crew performs actions based on symptoms that are described in the EOPs, not based on specific accident assessment.
Similarly, the Shift Manager/ED uses flowcharts in NMP-EP-112, Protective Action Recommendations procedure, which prescribes the decision-making processes for directing on-site protective measures.
The simple information needed to accomplish this allows for rapid decision making by the Shift Manager/ED using readily available information.
The Safety Parameter Display System (SPDS) provides the control room with a display of plant parameters from which the status of plant operation can be assessed.
The SPDS has the following functions:
- Aids the control room operators in the rapid detection and identification of abnormal operating conditions.
El13-4 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation
- Provides additional specific information to analyze and diagnose the cause of abnormal operating conditions.
- Monitors plant response to corrective actions.* Provides grouping of parameters to enhance the operators' capability to assess plant status quickly without surveying all control room displays concurrently.
- Directs the operators' attention to other specific confirmatory non-SPDS control room displays.* Provides human factors engineered display formats in simple and consistent display patterns and coding.* Provides display information on a real-time basis, along with validation of data.* Provides generated selectable trend displays on a real-time basis for monitoring reactivity control, reactor core cooling and heat removal from the primary system, reactor coolant system integrity, radioactivity Control, containment integrity, and other selected parameters.
Therefore, with the proposed changes, the ERO augmentation time continues to meet the intent of the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b).This Functional Area includes three tasks: Emergency Operations Facility (EOF) Emergency Director; Off-Site Dose Assessment and Chemistry/Radiochemistry; and Off-site, On-Site (out of plant), In-Plant Surveys, and Radiation Protection.
Emergency Operations Facility (EOF) Emergency Director (ED)The Technical Support Center (TSC) ED is not assigned to the on-shift complement.
In the current plan, the TSC ED arrives within about 60 minutes of notification of an Alert or higher emergency classification and relieves the on-shift ED of overall emergency management as well as all off-site responsibilities including Protective Action Recommendations (PARs) and emergency notifications.
The EOF is also staffed within this timeframe; however, there is currently no ED provided in the Emergency Operations Facility (EOF).Under this proposal, within 75 minutes of classification the Shift Manager/ED is relieved in the TSC by the ED, who then assumes overall control of the response efforts. The EOF ED arrives and relieves the TSC ED of overall emergency management and off-site responsibilities including PARs, dose assessment, and emergency notifications.
This ensures that in the unlikely event of an HAB event in which the site is not accessible to the ERO, sufficient personnel to perform the Radiological Accident Assessment and Support of Operational Accident Assessment function will be available in the EOF within 75 minutes from time of an Alert or higher declaration and minimize the burden on the Shift Manager/ED.
As discussed earlier, the overall function is enhanced by providing a Shift Manager to fill this function as a standalone position beyond the collateral assignment as designated by NUREG-0654/FEMA REP-01 Revision I Table B-I, during the period prior to augmentation.
The proposed change presents no adverse impact to the ERO staffing because the TSC and EOF EDs will continue to provide timely relief to the on-shift ED from the duties and responsibilities for offsite functions.
Offsite Dose Assessment (ODA) / Chemistry NUREG-0654IFEMA REP-Ol Revision 1 does not provide for on-shift dose assessment capability.
The current version of the VEGP Unit 3 and Unit 4 Emergency Plan does provide for an on-shift capability for performance of dose assessment and is currently assigned to an on-shift RP individual.
In the proposed change, on-shift dose assessment will be E13-5 Enclosure 13 to NL-15-1 392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation assigned to appropriately trained Chemistry personnel who will be dedicated to this task with no other collateral emergency response duties. This will in turn free the RP individual to perform other radiation protection related tasks. This position will be shared for the VEGP site, as the dose assessment program supports performing dose assessment for all units on the VEGP site in multi-unit and multi accident scenarios.
With the improvements to the dose assessment software program, as well as plant status, meteorological, and radiation monitoring data, Chemistry can perform dose assessments easily and rapidly during emergency conditions.
Enhancements in dose assessment software have reduced the time required to perform dose assessment runs and provide the results to the ED. In addition, the dose assessment software is operational in a Windows operating system located on the SNC Local Area Network (LAN) and as such can be readily accessed from any LAN computer on the SNC network.A second Chemistry individual is provided as part of the minimum on-shift staffing for VEGP Unit 3 and Unit 4 so that any required chemistry samples may be collected without impacting the Chemistry individual assigned to perform dose assessment.
A review of the Emergency Operations Procedures (EOPs), Abnormal Operating Procedures (AOPs), VEGP Unit 3 and Unit 4 Emergency Plan, and the procedures used by Operations for off-normal plant conditions did not identify any conflicts between completion of dose assessment and other on-shift Chemistry functions within the 75 minute augmentation time frame. An additional Chemistry support individual will be augmented in the TSC within 75 minutes, who will provide oversight for chemistry sampling and analysis activities.
An additional Chemistry technician will be augmented in the OSC within 75 minutes to assist in performing chemistry sampling and analysis.Augmentation by the RP Supervisor TSC within 75 minutes will relieve the Shift Manager/ED of the role of oversight of the on-shift dose assessor.
The TSC will retain this task until relieved by the EOF dose assessment staff, which consists of the Dose Assessment Supervisor and Dose Analyst. There is no loss of function or impact on the timing for performing either of the tasks of dose assessment or required radiochemistry sampling by the proposed on-shift staffing provided in the SNO Fleet Emergency Plan.Offsite/Onsite Surveys, In-Plant surveys and Radiation Protection (RP)NUREG-0654/FEMA REP-01 Revision 1 identifies one on-shift RP Technician who is responsible for performing in-plant surveys. NUREG-0654/FEMA REP-Ol Revision 1 does not provide for any on-shift personnel for on-site out of plant surveys or for off-site surveys.NUREG-0654/FEMA REP-O1 Revision 1 further identifies two Radiation Protection (RP)technicians under the Protective Actions function for performing the tasks of Access Control, Radiation Protection coverage for repair, corrective actions, search and rescue, first aid, firefighting, personnel monitoring, and dosimetry.
However, a note modification provides that these individuals may be assigned other functions, for example, the RP technician assigned to in-plant surveys task and the individual assigned to the Chemistry/Radio-chemistry task under the Radiological Accident Assessment and Support of Operational Accident Assessment function.As part of the proposed SNC Fleet Emergency Plan for VEGP Unit 3 and Unit 4 on-shift staffing, the on-site out of plant survey task will be performed by a single RP technician or other appropriately trained individual shared with VEGP Unit 1 and Unit 2. SNC currently uses predesignated, readily accessible survey points around the VEGP site for collecting on-site survey data. Prior to dispatch of the on-site out of plant monitoring technician, the dose assessor will brief the survey technician on the event conditions, direction of potential/actual plume path, potential radiological conditions, and so forth. The technician E1 3-6 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation will be dispatched to one of the predesignated sample points in the downwind direction of the potential/actual plume path. The survey technician will then obtain the pre-staged on-site out of plant survey kit and vehicle and proceed to the designated location.
The dose assessor and the survey technician will have the capability to maintain near continuous communications, which will allow the dose assessor to redirect the technician while in route if needed. Since the designated sample points are on-site and readily accessible from the VEGP site road system, there will be no immediate need for the survey technician to travel off-site and this survey can be performed by a single individual without impacting the accuracy or timeliness of the survey.Additionally, the proposed SNC Fleet Emergency Plan VEGP on-shift staffing will eliminate the on-shift individual coordinating communications between the out of plant survey technician and the dose assessor, and instead has the survey technician communicate directly with the dose assessor.
This will expedite communication of field survey readings to the dose assessor for input into the dose assessment program, resulting in a shorter completion time of dose assessment runs using actual field survey results.The proposed staffing for the SNC Fleet Emergency Plan augments an additional off-site survey team within 75 minutes of an Alert or higher emergency for the VEGP site as well as maintaining the augmentation of the EOF Field Team Coordinator and Field Team Communicator positions currently provided.Installed effluent radiation monitors and in-plant radiation monitors are able to detect any radioactive release quickly and accurately.
The enhanced technology provided by the Integrated Plant Computer (IPC) system and the dose assessment computer model provides reliable visual indication of any radioactive plume and its calculated direction.
Quantification of a radioactive release is determined by dose assessment, which is performed by dedicated on-shift personnel then augmented by additional dose assessment personnel in the TSC and EOF. On-site out of plant field teams and off-site field teams are typically used to verify the status of a potential release and validate the dose assessment model. Dose assessment model validation strategies developed and implemented by the EOF staff typically include directing one team to track the leading edge of the radiological plume, and one team to define the lateral edges of the plume and determine plume centerline radiological conditions.
If the field team survey data indicates a departure from the dose assessment model, the radiation surveys and air samples collected by these two field teams can be used to perform dose assessment back calculations.
SNC believes the two proposed field monitoring teams will be satisfactory for performing these surveys. To better support performing surveys off-site, the on-shift field team, which initially consisted of a single RP technician or other appropriately trained individual, can be augmented by the on-shift dose assessor as a vehicle driver (once relieved by the EOF Dose Analyst).
Sufficient instrumentation, communication equipment, and transportation will be maintained on-site for augmenting and dispatching additional teams if needed.Regarding in-plant surveys, Revision 3.0 of the VEGP Unit 3 and Unit 4 Emergency Plan provides for two RP technicians to perform in-plant surveys. However, these individuals are provided under the Protective Actions function.
The proposed SNC Fleet Emergency Plan VEGP Unit 3 and Unit 4 on-shift staffing provides one RP technician assigned to the task of in-plant surveys under the Radiological Accident Assessment and Support of Operational Accident Assessment function.
An additional RP technician will be provided for VEGP Unit 3 and Unit 4 for the Protective Actions function discussed later. However, since both of these individuals are qualified RP technicians, they will be available to collectively support either of these functions as needed. An additional two Radiation Protection technicians will respond within 75 minutes to support Radiological Accident Assessment (in-plant) function El13-7 Enclosure 13 to NL-15-1 392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation for the VEGP site. This will provide sufficient Radiation Protection resources to address the Radiological Accident Assessment needs of both the on-shift and augmented ERO personnel.
With improved installed instrumentation, dose calculation computer modeling, and dedicated on-shift staffing for dose assessment and on-site out of plant surveys, there is no more than minimal impact to the performance of these tasks as a result of the proposed staffing alignments in the SNC Fleet Emergency Plan.Plant System Engineering This functional area includes two tasks: Technical Support, and Repair and Corrective Actions Technical Support NUREG-0654/FEMA REP-0l Revision 1 guidance provided for a Shift Technical Advisor (STA)to be available on-shift to perform the Technical Support task including core/thermal hydraulics in response to the NUREG-0737 requirements resulting from the Three Mile Island accident.Subsequently, the NRC modified this position with the guidance of "Commission Policy Statement on Engineering Expertise on Shift" published in Federal Register Notice 50 FR 43621, dated October 1985. Based on this Commission Policy Statement, the Current VEGP Unit 3 and Unit 4 Emergency Plan assigns the STA task as a collateral duty to an STA qualified SRO assigned to other functions.
The proposed SNC Fleet Emergency Plan staffing for VEGP Unit 3 and Unit 4 continues to identify this task as fulfilled by an individual holding the STA qualification as a collateral duty of appropriately qualified on-shift personnel that may also be assigned to another function.
This will typically be assigned to either the Shift Manager or another on-shift Senior Reactor Operator (SRO). The performance of this task as a collateral duty includes the use of the IPC, which graphically displays the pertinent parameters with trending and graphing capabilities, alarm functions, and color coded indication for changes in state for various critical safety parameters,.
This enhances critical parameter monitoring and the rapid identification and assessment of in plant conditions.
Repair and Corrective Actions NUREG-0654/FEMA REP-0l Revision 1 Table B-i specifies the functional area of Repair and Corrective Actions is to be provided on-shift by a total of two individuals who also "may be provided by shift personnel assigned other functions." It further states that the "position title or expertise" for the Repair and Corrective Actions task could be filled by Mechanical Maintenance/Radwaste Operator, Electrical Maintenance, or l&C Technician.
Due to the time needed to stabilize the plant and assess the event, the initial phase of an accident is not expected to involve a significant need for maintenance personnel.
Once plant status is understood and the plant is in a stable condition, attention can be focused on corrective maintenance that may be needed to restore plant capabilities.
Typically, the initial stages of Corrective Actions are minor or of limited scope, such as:* Mechanical
-Identification and operation of faulty valves, clogged filters, packing and seal adjustments, or troubleshooting.
- Electrical
-Identification and correction of tripped breakers and overloads, or hands-off troubleshooting.
- I&C -Identification and correction of controller and set point adjustment, calibration, or hands-off troubleshooting.
E13-8 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation Until the reactor is stabilized and the causal agents identified, actual repairs or realignment of plant equipment would not require large-scale maintenance support. The current version of the VEGP Unit 3 and Unit 4 Emergency Plan provides for one mechanical journeyman, one electrical journeyman, and one instrument and controls technician on-shift to support the Repair and Corrective Action task. These numbers will be maintained in the proposed SNC Fleet Emergency Plan. However, these positions will be shared for the VEGP site as the maintenance personnel will be trained and qualified to perform work on VEGP Units 1 and 2 and Units 3 and 4. In addition to these personnel, a maintenance supervisor will be added to shift to provide, supervisory oversight for repair and corrective actions, further enhancing the on-shift response capability.
This position will also be shared for the VEGP site. A 10 CFR 50 Appendix E shift staffing evaluation has demonstrated that no maintenance personnel were assigned tasks during the 75 minutes prior to augmentation.
Additionally, the proposed SNC Fleet Emergency Plan provides for augmentation of maintenance discipline specific leads in the OSC, as well as an overall OSC Manager, within 75 minutes of an Alert or higher emergency classification.
The NRC Public Meeting on July 16, 2015 discussing proposed changes to guidance regarding ERO staffing and augmentation (ML15174A309) identified that the proposed change primarily meets or exceeds the current regulatory guidance of NUREG-0654/FEMA REP-01 Revision I Table B-I and the proposed NUREG-0654/FEMA REP-01 Revision 2.Based on VEGP Unit 3 and Unit 4 licensing basis (FSAR), the design philosophy with respect to Engineered Safety Features (ESE) and guidance for restoration, it is unnecessary to have additional Mechanical Maintenance, Electrical Maintenance, and I & C Maintenance augmented within the 75 minute timeframe.
ESF systems are passive, redundant, and have diversity of subsystems.
Therefore, the inoperability of different system components is not anticipated to result in a loss of function of the ESF. This allows flexibility in plant operations under circumstances where components in redundant subsystems may be inoperable.
Furthermore, the passive design of VEGP Unit 3 and Unit 4 does not anticipate significant oPerator action or maintenance support for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a design basis accident.Protective Actions (In-Plant)
For the Protective Actions (In-Plant) function, NUREG-0654/FEMA REP-01 Revision I specifies providing two personnel on-shift who "may be provided by shift personnel assigned other functions." The major tasks of this function are access control, RP coverage for repair, corrective actions, search and rescue, first aid, firefighting, personnel monitoring, and dosimetry.
Revision 3.0 of the VEGP Unit 3 and Unit 4 Emergency Plan provides two individuals for performing this function.System Operators are typically dispatched prior to the call-out of augmented personnel.
Normally the initial response phase involves search and rescue operations or manual manipulation of equipment.
Maintenance actions in the initial response phase are anticipated to be minimal as discussed previously.
Installed plant area radiation monitors are used to provide indication of in-plant radiation levels prior to dispatch of personnel into the plant. This allows for personnel to be assigned the appropriate dose and dose rate alarms for their electronic personal dosimetry prior to dispatch and to assign additional Radiation Protection technician support as needed.Personnel accessing the Radiological Control Areas (RCA) at VEGP Unit 3 and Unit 4 are required by procedure to obtain electronic personal dosimetry prior to entry. The same dosimetry is also used as a "key" to unlock turnstiles for access to the RCA. Radiation work permits (RWPs) establish the necessary preset warnings/alarms associated with the dosimetry.
During a declared emergency, the normal RCA entry process may use pre-prepared emergency E13-9 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation RWPs using the Digital Alarming Dosimeters (DADs). In the event the normal access system is non-functional, an emergency reentry process has been developed to use the pre-prepared emergency RWP dose and dose rate alarms manually programed into the DADs. This ensures the teams dispatched to in-plant areas to perform any function during a declared emergency will be afforded ample warning/alarm before exceeding their allowed dose or dose rate. In-plant teams are briefed regarding radiological conditions prior to being dispatched, including plant event conditions, radiological conditions, dose and dose rate turn back values/alarms, and communications methods to be used if radiological conditions change or if unexpected radiological conditions are encountered.
Thus, under emergency conditions, responding personnel will be knowledgeable of dose rates in the area, and radiation protection personnel may not be required to accompany all teams into the plant areas. Dosimeters also can be programmed at the OSC by RP personnel as needed prior to team dispatch.
The proposed SNC Fleet Emergency Plan VEGP Unit 3 and Unit 4 on-shift staffing provides for a total of two Radiation Protection technicians between the Protective Actions (in-plant) and Radiological Accident Assessment (in-plant surveys) to ensure appropriate radiological protective measures are available to the on-shift staff.An additional two Radiation Protection technicians and an RP/Chemistry OSC lead will be augmented in the OSC within 75 minutes to support the Protective Actions (in-plant) function for the VEGP site. This will provide sufficient Radiation Protection resources to address the needs of both the on-shift and augmented ERO personnel for the Protective Actions (in-plant) function.Fire Fighting There are no proposed changes to the Fire Fighting function.
The on-shift Fire Brigade is assigned this task throughout the emergency with off-site support provided by local fire departments.
A staffing analysis meeting the requirements of 10 CFR 50 Appendix E.IV.A.9 for the proposed organization was performed.
The results of that analysis showed that the required response functions could be conducted with parallel activation of the fire brigade for the subject scenarios.
Rescue Operations and First Aid Per NUREG-0654/FEMA REP-01 Revision 1, the Rescue Operations and First Aid function"may be provided by shift personnel assigned other functions." The VEGP Unit 3 and Unit 4 Emergency Plan uses appropriately trained on-shift personnel to fulfill this function as a collateral duty. The proposed SNC Fleet Emergency Plan provides that the existing personnel assigned this function will be maintained.
However, these positions will be shared for the VEGP site. There are no additional personnel augmented for this task. Local off-site support provides for any additional assistance.
There are no proposed changes to this area; therefore, there is no impact represented by the change in augmentation times.Site Access Controls and Personnel Accountability There are no proposed changes to this area. This function is part of the Security Contingency Plan and is staffed accordingly.
Onsite Emergency Response Organization (ERO) -10 CFR 50.47(b) (2)The current ERO was developed in response to NUREG-0654/FEMA REP-01 Revision 1. The ERG developed by NUREG-0654/FEMA REP-01 Revision 1 was developed without a specific technical basis. The Emergency Preparedness Enhanced Rulemaking of November 23, 2011 El13-10 Enclosure 13 to NL-1 5-1 392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation required the capabilities of the on-shift staff to be validated by a formal analysis.
This requirement was documented in 10 CFR 50 Appendix E.IV.A.9.
In support of this submittal, the proposed ERG for the VEGP Unit 1 and Unit 2 Site was analyzed and it was determined that the on-shift staff proposed is capable of performing the response functions required of the revised rule.Reason for the Change The proposed ERG in the SNC Fleet Emergency Plan provides a standard complement of emergency response positions, titles, duties, and responsibilities.
This will result in a more effective interface between ERG members at the sites and their counterparts at the SNO Fleet EOF. Having a common ERG organization for the SNO Fleet will also support sharing of ERG resources between affected and non-affected stations during emergencies.
Establishing an appropriately staffed SNC Fleet standard on-shift and an augmented ERG staffing model with an SNC Fleet standard definition for ERG augmentation time is a practical and prudent alternate method to ensure effective and timely emergency response augmentation.
Details associated with the on-shift ERG, revised augmented ERG, and revised key responsibilities and tasks as identified in NUREG-0654/FEMA REP-01 Revision 1, are included in Enclosure 15.Planning Basis for Auqmented Emergency Response Organization (ERO)Positions have been designated as 75 minutes responders in the TSC, OSC, EGF, and JIC.These positions perform major functions and supporting functions in each facility.
The tables below outline these positions and functions as provided in the proposed SNC Fleet Emergency Plan.E13-11 Enclosure 13 to NL-15-1 392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation TSC 75 Minute Augmentation ERO Major Functional Area Major Task Position Title Emergency Director (ED)TSC Manager Emergency Direction and Operations Supervisor Control Security Supervisor*
______________________Support Coordinator**
Notify licensee, state, local, Emergency Notification and federal personnel
& System (ENS) Communicator Notification/Communication maintain communication HPN Communicator intra-facility Communications Emergency Response Facility (ERE) Communicator Offsite Dose Assessment Radiation Protection (RP)Radiological Accident Supervisor Assessment and Support of OfiesresNtapial o hsfclt Operational Accident OfiesresNtapial o hsfclt Assessment Onsite and in-plant surveys Chemistry/Radio Chemistry Chemistry Support Technical Support Engineering Supervisor Reactor Engineer Engineering Support (2)Plant System Engineering, Repair and Corrective Actions Repair and corrective Maintenance Supervisor actions Access Control Not applicable for this facility RP coverage for repair, corrective actions, search Protective Actions and rescue, first aid &firefig hting Personnel monitoring
____ ____ ___ ____ ____ ___ Dosimetry_
_ _ _ _ _ _ _ _ _ _ _ _ _*Security Supervisor filled by one of the on-shift Security Supervisors.
- Support Coordinator does not have a 75 minute augmentation time.El13-12 Enclosure 13 to NL-1 5-1 392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation OSC 75 Minute Augmentation ERO Major Functional Area Major Tasks Position Title Emergency Direction and OSC Manager Control Notify licensee, state, local, Not applicable for this facility and federal personnel
&Notification/Communication miti omncto Intra-facility communications ERF Communicator RadolgialAcidntOffsite Dose Assessment Not applicable for this facility AssmnanSuprof Offsite surveys Field Monitoring Team Assesmet ad Supor ofPersonnel (2)Opertioal ccientOnsite and in-plant surveys RP Technicians (2)AssssmntChemistry/Radio Chemistry Chemistry Technician Technical Support Not applicable for this facility Repair and corrective Mechanical Maintenance Plant System Engineering, actions Group Lead Repair and Corrective Actions Electrical Maintenance Group Lead____________________I&C Maintenance Group Lead Access Control RP / Chemistry Group Lead* RP coverage for repair, RP Technicians (2)corrective actions, search Protective Actions and rescue, first aid &firefighting
- Personnel monitoring
- Dosimetry El13-13 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation EOF 75 Minute Augmentation ERO Major Functional Area Major Task Position Title Emergency Direction and EOF Director ED Control EOF Manager Support Coordinator**
Emergency Communication Coordinator Security Coordinator Offsite Response Coordinator Administrative Support Staff **Liaisons (at EOCs)**-GA-AL-SC Notification/Communication Notify licensee, state, local, ENN Communicator and federal personnel
& ENS Communicator maintain communication HPN Communicator Intra-facility ERF Communicator Communications Nuclear Spokesperson Technical Assistant News Writer Field Team Communicator Radiological Accident Offsite Dose Assessment Dose Assessment Supervisor Assessment and Support of Dose Analyst Operational Accident Offsite surveys Field Team Coordinator Assessment Onsite and in-plant surveys Not required in this facility Chemistry/Radio Chemistry Not required in this facility Plant System Engineering, Technical Support Technical Supervisor Repair and Corrective Actions Repair and corrective Not required in this facility actions _______________
Protective Actions Access Control Not required in this facility RP coverage for repair, corrective actions, search and rescue, first aid &firefighting Personnel monitoring
_______________________
Dosimetry** Support Coordinator, Administrative Support Staff, Liaisons (at EOCs) GA, AL, SC do not have a 75 minute augmentation time.E13-14 Enclosure 13 to NL-15-1 392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation JIC 75 Minute Augmentation ERO Functional Area Major Task Position Title Media Response Media Response Public Information Director ERF Communicator JIC Manager JIC Assistant**
Facility Coordinator**
Clerical Staff**Security**
Public Response Coordinator Public Response Staff**Media Relations Representative
- JIC Assistant, Facility Coordinator, Clerical Staff, Security, and Public.Response Staff do not have a 75 minute augmentation time.Minimum staff positions have been identified for each facility.
Facility activation may be completed upon filling of minimum staffing positions and completion of a briefing on the event to ensure personnel in these positions are ready to accept responsibility for their functions.
Minimum staffing positions for the TSC Organization are as follows:* TSC Emergency Director (ED)* TSC Emergency Response Facility (ERF) Communicator
- TSC Engineering Supervisor Minimum staffing positions for the Operations Support Center (OSC) Organization are as follows:* OSC Manager* OSC Emergency Response Facility (ERF) Communicator
- OSC RP/Chemistry Group Lead Minimum staffing positions for the EOF Organization are as follows:* EOF Emergency Director (ED)* EOF Emergency Response Facility (ERF) Communicator
- EOF Dose Analyst* EOF ENN Communicator Minimum staffing positions for the Joint Information Center (JIC) Organization are as follows:* Public Information Director (PID)* Emergency Response Facility (ERF) Communicator El13-15 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation
- JIC Manager* Media Relations Representative
- Public Response Coordinator In addition to the functional analysis provided, the key Emergency Response Facilities were analyzed to determine the minimum staffing (both numbers and positions) needed for the facilities to activate the facilities and begin facility operations.
Any personnel determined to be required to support the minimum staff activation and initiation of activities were added to the revised augmented ERO.Program Enhancements The following section discusses technical aspects of plant systems, dose assessment, procedures, and training which support on-shift functions and ease operator burden. Additional information regarding on-shift and augmented positions and their responsibilities as identified in NUREG-0654/FEMA REP-O1 Revision 1 are included in Enclosure 15.Plant Computer System The VEGP Unit 3 and Unit 4 Safety Parameter Display System (SPDS) is a state of the art system integrated into the overall man-machine interface for VEGP Unit 3 and Unit 4. It provides a display of plant parameters from which the status of operation can be assessed, in the control room and in the onsite and off-site Emergency Response Facilities (ERFs).This state of the art SPDS:* Aids the control room operators in the rapid detection and identification of abnormal operating conditions.
- Provides additional specific information to analyze and diagnose the cause of abnormal operating conditions.
- Monitors plant response to corrective actions.* Provides grouping of parameters to enhance the operators' capability to assess plant status quickly without surveying all control room displays concurrently.
- Directs the operators' attention to other specific confirmatory non-SPDS control room displays.* Provides human factors engineered display formats in simple and consistent display patterns and coding.* Provides display information on a real-time basis, along with validation of data.* Provides generated selectable trend displays on a real-time basis for monitoring reactivity control, reactor core cooling and heat removal from the primary system, reactor coolant system integrity, radioactivity control, containment integrity, and other selected parameters.
The SPDS in the control room consists of displays of sets of concentrated parameters from which plant safety status can be rapidly assessed.
Duplicate SPDS displays are located in the El13-16 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation TSC and EGE to maximize the exchange of information between these facilities and the control room. The SPDS in each facility is a peripheral of the Integrated Plant Computer (IPC) system.The Integrated Plant Computer gathers, stores, and displays data used by TSC and EOF personnel to analyze plant conditions.
The IPC performs this function independently of actions in the control room and without degrading or interfering with control room and plant functions.
The IPC consists of workstations, printers, video copiers, and associated computer hardware and software.
The IPO serves as the primary data acquisition system for emergency response, acquiring, processing, and feeding data to the TSC and the Safety Parameter Display System (SPDS). In addition, data links are provided to other locations including the EOF.Dose Assessment Radiological dose assessment has benefited from technological advances that make performance of dose assessment simpler and less time-consuming.
Dose assessment is currently performed by on-shift RP personnel using the MtDAS-NU program. This program supports multi-unit and multi-accident assessment of radiological releases.
The MIDAS-NU program has minimal data entry needs and a minimal number of program windows the user needs to access to perform a dose projection.
With the use of the dose assessment program, as well as plant status, meteorological, and radiation monitoring data, one person can easily and rapidly perform dose assessments during emergency conditions.
Specifically designed displays have been developed for obtaining the necessary plant, radiological effluent, area radiation monitor, and meteorological information for dose assessment personnel on-shift using the Meteorological Information Dose Assessment System-Nuclear (MIDAS-NU) program.Automated Call-Out System Automated call-out systems have been enhanced to streamlined processes for activation of the ERO. A single phone call initiates rapid notification of ERO members, in lieu of individual calls to fill the ERO positions included in the Emergency Plan. The system includes a primary activation location as well as a remotely located back-up capability to ensure uninterrupted operation.
Procedure Improvements Emergency Operations Procedures (EOPs)lAbnormal Operating Procedures (AOPs)Since the original emergency plan approval, EOPs have been improved through industry initiatives.
EOPs now use a symptom-based approach that demands less assessment and interpretation of plant conditions by the operating crews. EOPs interface well with new technology such as IPC. EOP curves are generated by IPC to graphically display plant conditions relative to limits or required actions.Emergency Plan Implementing Procedures (EPIPs)Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 uses a classification methodology based on NEI 07-01 guidance.
This EAL guidance has improved the classification process, including the use of an overview matrix of EAL initiating conditions and threshold values, which streamlines the process of evaluating EALs against plant conditions.
El13-17 Enclosure 13 to NL-1 5-1 392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation Training Improvements Operations Training Training is used to strategically drive improved performance at Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4. The application of the Systematic Approach to Training (SAT) resulted in developing a task list for Operations personnel.
The SAT process ensures training is conducted to industry-accepted standards and has led to accreditation of the Operations Training Programs by the National Academy for Nuclear Training.A dynamic simulator will be used during Operations Training.
Simulator evaluations include emergency response scenarios that will periodically exceed 75 minutes in length and will be part of the requalification cycle. Simulator scenarios will be designed to be realistic and reflect a wide range of plant conditions, including emergency conditions.
During evaluated simulator sessions, the control room staff will be presented with a variety of plant conditions from normal operation to accident conditions resulting in declaration of at least one event.These events can range from Unusual Event to General Emergency.
The crews will perform critical tasks, classification, accident mitigation, response prioritization, and communications without augmentation from additional responders.
The proficiency of the control room staff to perform these functions while maintaining situational awareness, without additional support will be assessed in every training cycle.The Licensed Operator Requalification (LOR) Training Program will include licensed crew performance evaluations that consider the scenario guidance attributes of INPO Operations Department Standing Instruction, ODSI-3, and Operations Department Guidance.Attachment C of ODSI-3 provides guidance on the realistic integration of the emergency response into crew performance evaluations.
The purpose is to ensure the crew performance evaluations realistically represent the additional challenges that the emergency plan responsibilities add to the crew's ability to manage an event. Representing the event as realistically as possible, which includes the additional challenges of emergency plan responsibilities, helps promote the situational awareness necessary during a real event.STA Training The Shift Technical Advisor (STA) was originally trained as an advisor to the operating shift per NUREG-0737.
In 1990, additional guidelines were developed by INPO for the training of STAs. This is detailed in the document INPO 90-003, Guidelines for Training and Qualifications of Shift Technical Advisors.The INPO Guidelines describe the role of the STA. The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, development of recommendations to protect the public and any other actions related to critical safety functions and plant safety during abnormal and emergency situations.
By routinely monitoring equipment and plant operations, the STA can focus on preventive actions in order to mitigate the consequences of an accident and protect'public health and safety.Increases in On-Shift Staffing The regulatory guidance provided by NUREG-0654/FEMA REP-O1 Revision 1 requires a total of 10 persons. The staffing proposed for VEGP Unit 2 and Unit 3 significantly exceeds this guidance.
A comparative chart depicting on-shift and augmented staffing based on NUREG-0654/FEMA REP-0l Revision 1, Revision 3.0 of the Vogtle Electric Generating Plant (VEGP)El13-18 Enclosure 13 to NL-15-1392 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation Unit 3 and Unit 4 Emergency Plan, and the staffing proposed in the SNC Fleet Emergency Plan is included in Enclosure15.
Enhancements in Information Sharing with Offsite Agencies There has been a dramatic increase in the ability of the site to share event specific information with Offsite Response Organizations (OROs) from the one-to-one telephone systems existing at the time NUREG-0654/FEMA REP-O1 Revision 1 was approved.
Real-time plant data is communicated to the Nuclear Regulatory Commission using the approved Emergency Response Data System (ERDS). Additionally, local OROs are provided rea- time data with automated methods (currently WebEOC). These enhancements provide more timely and accurate information of actual, plant conditions than was originally available Improvement Summary The improvements in reactor technology, staffing, equipment, procedures, communication of plant information, and training since initial approval of NUREG-0654/FEMA REP-O1 Revision 1 have resulted in a significant increase in on-shift capabilities and knowledge.
The ERO maintains the depth and capability for. continuous 24-hour coverage of the Emergency Response for a protracted period.Summary Based on the overall improvements in technology, procedures, training, and staffing levels available to ERO since the original implementation of the guidance contained in NUREG-0654/FEMA REP-O1 Revision 1, the proposed Emergency Response Organization is capable of implementing the Emergency Plan in accordance with the requirements of 10 CFR 47 and 10 CFR 50 Appendix E.El13-19