RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation
| ML16124A002 | |
| Person / Time | |
|---|---|
| Issue date: | 08/05/2016 |
| From: | Michael Cheok, Louise Lund Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking |
| To: | |
| Harris B, NRR/DPR, 301-415-2277 | |
| References | |
| TAC MF7013 RIS-16-010 | |
| Download: ML16124A002 (14) | |
ML16124A002 UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
WASHINGTON, DC 20555-0001
August 5, 2016
NRC REGULATORY ISSUE SUMMARY 2016-10
LICENSE AMENDMENT REQUESTS FOR CHANGES TO EMERGENCY
RESPONSE ORGANIZATION STAFFING AND AUGMENTATION
ADDRESSEES
All holders of an operating license or construction permit for a nuclear power reactor under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities.
All holders of a power reactor early site permit or combined license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to inform addressees (hereinafter referred to as licensees) of the application of guidance documents to support license amendment requests (LARs) that change augmenting emergency response organization (ERO) arrival times. This RIS is based on a number of recent LAR
submittals that did not properly justify proposed ERO changes. Specifically, the NRC has identified the need to clarify the application of the Nuclear Energy Institute (NEI) document NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, dated June 23, 2011.1 In addition to the clarification this RIS provides, the RIS will assist licensees by providing examples of the scope and detail of information that should be provided in the LARs to facilitate the NRC review. This RIS requires no action or written response on the part of a licensee.
BACKGROUND INFORMATION
All nuclear power reactor licensee emergency plans have an on-shift staff complement for coping with emergencies with a predetermined level and timing of staff augmentation in key functional areas.
The on-site emergency response plan regulations in 10 CFR 50.47(b)(2) state, in part, that on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, [and] timely augmentation of response capabilities is available.
1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML111751698. NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 30, 1980,2, 3 referred to as NUREG-0654, offers guidance on how to assess emergency response staffing needs. Relevant portions of NUREG-0654 are detailed below:
Section I, Introduction, paragraph D, Planning Basis, states, in part, that:
No single specific accident sequence should be isolated as the one for which to plan because each accident could have different consequences, both in nature and degree. Further, the range of possible selection for a planning basis is very large, starting with a zero point of requiring no planning at all because significant offsite radiological accident consequences are unlikely to occur, to planning for the worst possible accident, regardless of its extremely low likelihood.
In addition,Section II, Planning Standards and Evaluation Criteria, paragraph B, Onsite Emergency Organization, item 5 states, in part, that:
Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.
In 2011, the NRC amended 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, that, in part, added Section IV.A.9, which requires nuclear power reactor licensees [to provide by December 24, 2012] a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. As noted, in part, in the Statements of Consideration for this change (76 Federal Register 72559, 72564; November 23, 2011):
The NRC expects the analysis to identify all the tasks that must be performed by available staff during an evolution such as response to an emergency. These licensees need to define the events that will be used in the detailed staffing analysis, such as postulated design basis accidents and the DBT [design basis threat], for which there must be emergency planning. The analysis must identify all tasks that must be completed for each analyzed event, and the responders
2 ADAMS Accession No. ML040420012.
3 Regulatory Guide 1.101, Emergency Response Planning and Preparedness for Nuclear Power Reactors, Revision 2, endorses NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, to be an acceptable method for complying with the requirements in 10 CFR Part 50, Appendix E, and the planning standards in 10 CFR 50.47(b). responsible for the performance of those tasks. Licensees must then ensure that there is sufficient on-shift staff to perform all necessary tasks until augmentation staff arrives to provide assistance.
NEI developed NEI 10-05 to establish a standard method for analyzing on-shift staffing as required by Section IV.A.9 to Appendix E of 10 CFR Part 50. The NRC endorsed the on-shift staffing method of NEI 10-05 in Section IV.C of the interim staff guidance (ISG),
NSIR/DPR-ISG-01, Interim Staff GuidanceEmergency Planning for Nuclear Power Plants, dated November 2011,4 by stating the NRC has reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose. The NRCs endorsement of NEI 10-05 is limited to the method for developing an on-shift staffing analysis (the context in which it appears in the ISG) and does not extend to any other application of NEI 10-05.
Criteria to be Considered for the On-Shift Staffing Analysis
In addition to the endorsement of NEI 10-05 as one acceptable method for developing an on-shift staffing analysis, NSIR/DPR-ISG-01 established criteria for the series of specific accident scenarios that must be considered in the development of the on-shift staffing analysis.
The specific accident scenarios identified in NSIR/DPR-ISG-01 are:
(1) postulated design-basis accidents (DBAs) (Condition IV events) presented in the final safety analysis report, as updated, and which would result in an emergency declaration;
NOTE: At least one DBA should result in the declaration of a general emergency and radiological doses to the public that exceed the U.S. Environmental Protection Agencys Protective Action Guides and necessitate licensee protective action recommendations.
This analysis should be done even if no DBA defined in the licensing basis results in this emergency classification and dose levels.
(2) station DBT;
(3) response actions for an aircraft probable threat in accordance with
10 CFR 50.54(hh)(1), and as discussed in Regulatory Guide (RG) 1.214, Response Strategies for Potential Aircraft Threats; and
(4) control room fire leading to evacuation and remote shutdown, as referenced in Information Notice 1995-48, Results of Shift Staffing Study.5
Unlike the guidance provided in NEI 10-05 for the on-site staffing analysis, the planning basis for Table B-1 of NUREG-0654 is based on a wide spectrum of events. For the purposes of complying with the regulations in Section IV.A.9 to Appendix E of 10 CFR Part 50, scenarios have been identified in NSIR/DPR-ISG-01 to facilitate these evaluations for analyzing on-shift staffing to determine if collateral duties exist that would impact the ability for the on-shift personnel to perform emergency planning functions. It should be noted that these specific scenarios are only applicable for performance of an on-shift staffing analysis, and are not applicable for evaluating ERO augmentation.
4 ADAMS Accession No. ML113010523.
5 ADAMS Legacy Library No. 9510040181. Content of License Amendment Requests Related to On-Shift Staffing and ERO Augmentation
Licensees proposing a change to its emergency plans that reduce the licensees capability to perform an emergency planning function in the event of an emergency must meet the requirements of 10 CFR 50.54(q)(iv)(4), which states:
The changes to a licensees emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of §§50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensees emergency plan, as revised, will continue to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of §50.47(b).
The information in RG 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, dated November 30, 2011,6 offers guidance on how to evaluate proposed emergency plan changes submitted to the NRC with LARs. Regulatory Position 4 of RG 1.219 provides the individual emergency planning functions associated with the planning standards of
10 CFR 50.47(b), along with explanatory guidance. It offers and explains examples of changes that could require prior NRC approval, and those that would generally not require prior NRC
approval. Changes to the ERO have the potential to affect its performance in the major functional areas and major tasks, and evaluations of the impact of such changes would necessarily involve other emergency planning functions.
Additionally, 10 CFR Part 50, Appendix E, Section IV.A.7, requires identification of, and a description of the assistance expected from appropriate State, local, and Federal agencies with responsibilities for coping with emergencies, including hostile action at the site. Therefore, changes in ERO on-shift or augmentation staffing levels and response times should be evaluated for their impact on the State and local response organizations ability to effectively implement their Federal Emergency Management Agency (FEMA)-approved radiological emergency preparedness (REP) plans, specifically in regard to licensee interface and coordination with State and local response organizations. [NOTE: In order to facilitate the NRC
review of the licensees plan change per 10 CFR 50.54(s)(3), any change to the licensees emergency plan that impacts or has the potential to impact State and local REP plans will be provided by the NRC to FEMA for review to verify that continued reasonable assurance exists that State and local emergency plans can be implemented. As such, an adequate evaluation and documentation of coordination with off-site response organizations should be provided as part of the licensees submittal.]
The functions and tasks associated with the implementation of mitigating strategies for beyond-design-basis (BDB) events (i.e., those functions and tasks required by NRC Orders EA-
12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,7 and EA-12-051, Order Modifying Licenses with
6 ADAMS Accession No. ML102510626.
7 ADAMS Accession No. ML12056A045. Regard to Reliable Spent Fuel Pool Instrumentation,8 and addressed by guidance in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,9 and NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)
Implementation Guide10) should not be considered in ERO staffing change assessments unless such functions and tasks are described in the site emergency plan. The site staffing assessment performed to respond to NRC letter, Request for Information Pursuant to Title 10
of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident,11 demonstrates the availability of sufficient staff to implement the emergency plan concurrently with BDB event response strategies and guidelines (i.e., those required to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling). Performance and maintenance of this BDB event response staffing assessment are addressed in the Mitigation of Beyond-Design-Basis Events proposed rule (80 Federal Register 70609; November 13,
2015).
SUMMARY OF ISSUE
The NRC staff has recently received multiple LARs that seek to change ERO staffing commitments by extending the augmentation time for certain positions, or eliminating the staffing for positions entirely. In each case, the change has been justified primarily by referencing the on-shift staffing analysis developed in accordance with NEI 10-05, or a similar analysis using different accident scenarios. These LARs indicate a misunderstanding on how NEI 10-05 and the associated staffing analysis can be used effectively in the justification of proposed staffing changes. Additionally, NRC staff seeks to clarify what constitutes adequate justification for a proposed change, and how the NRC will evaluate submitted LARs for staffing changes.
The guidance in NEI 10-05 focuses on the capabilities of the on-shift staff, specifically to identify collateral duties that could interfere with the performance of on-shift emergency preparedness (EP) functions/capabilities. NEI 10-05 does not consider the capabilities offered by the augmenting ERO staff to relieve and support on-shift staffing for the purposes of providing justification for extension of ERO response times. An on-shift staffing review using NEI 10-05 should ensure sufficient on-shift staff exists to perform all necessary EP functions and capabilities until augmenting ERO staff arrives, in accordance with the sites emergency plan commitments.
The guidance in NEI 10-05, Section 2.14, Changes to ERO Response Times, may be used to identify if there is an on-shift position that has the necessary training to perform a major task as described in NUREG-0654, Table B-1, but is not currently credited for performing EP functions and capabilities that are assigned to an augmenting responder. This would allow the assignment of an augmented major task to that on-shift position, thereby maintaining the capability to perform the major task of the emergency plan while eliminating the need for an augmented responder to perform the tasks. The reassignment of these tasks to the on-shift position would need to be reflected in the emergency plan. However, an evaluation performed using only the guidance of NEI 10-05 does not satisfy the requirement to identify and evaluate changes to ERO augmentation timing or ERO augmentation staffing that reduces the capability
8 ADAMS Accession No. ML12056A044.
9 ADAMS Accession No. ML12125A412.
10 ADAMS Accession No. ML16005A625.
11 ADAMS Accession No. ML12073A348. to perform an emergency planning function. Following the guidance from RG 1.219, LARs that seek approval for changes to on-shift staffing and the augmenting ERO (e.g., staffing levels, response timing) should identify each change and evaluate them individually.
All operating reactor licensees have an NRC-approved emergency plan that includes site-specific on-shift staffing and ERO augmentation time requirements. In addition to a site-specific evaluation, the NRC uses the minimum staffing guidance in Table B-1 of NUREG-0654 to evaluate LARs dealing with proposed changes to on-shift or augmented ERO
staffing. However, it is recognized that an alternate staffing approach may be acceptable, provided that initial facility accident response in key functional areas is maintained at all times, and there is timely augmentation of response capabilities. In support of a proposed LAR, a licensee should supply sufficient information to allow the NRC to conclude independently that a proposed alternate staffing approach supports timely and effective performance of the Major Functional Areas and Major Tasks listed in Table B-1 of NUREG-0654.
The NRC has extensive experience with the review of proposed changes to on-shift and augmented ERO staffing. This experience has allowed the staff to develop a consistent review and approval process for LARs related to ERO staffing changes. The following examples highlight some specific items that NRC staff consider when reviewing shift staffing change requests for augmented ERO positions as provided in NUREG-0654, Table B-1. The first example will outline considerations of an LAR for an extension of a 30-minute ERO
augmentation time to 60 minutes. The second example will outline the considerations of an LAR for an extension of a 60-minute ERO augmentation time to 90 minutes.
Considerations of the Review Process for Proposed Extensions of NUREG-0654, Table B-1 - 30-Minute ERO Augmentation Time to 60 Minutes
Notification and Communication
Table B-1 of NUREG-0654 assigns the major task of Notify licensee, State, local and Federal personnel [and] maintain communication to On Shift personnel with a note that this major functional area may be performed by engineering aide to shift supervisor, with one individual available within 30 minutes. To adequately support the proposed elimination or extension of the one 30-minute responder, licensees should show that equivalent capability is provided by on-shift staff to fill the responders responsibility to notify licensee, State, local and Federal personnel [and] maintain communication. For example, the 30-minute responder may be eliminated if an on-shift position is identified to fill this role. This on-shift position should not be assigned other tasks that may prevent the timely performance of their assigned notification or communication functions, as specified in the emergency plan. Alternatively, a licensee could demonstrate that communications technologies eliminate the need for an additional on-shift communicator. The NRC staff will consider whether the change basis adequately establishes that communication technologies employed by the proposed on-shift staff supports timely, effective, and reliable notifications. Additionally, the communications technologies should be referenced in the emergency plan to ensure that future changes are reviewed using the RG 1.219 change process, as they were used as the basis for the proposed change.
Off-site Dose Assessment
Table B-1 of NUREG-0654 assigns the major task of Offsite Dose Assessment as requiring augmented support by one individual within 30 minutes. To adequately support the proposed elimination or extension of the one 30-minute responder, licensees should identify an on-shift position as capable of initially filling the 30-minute responders role of Offsite Dose Assessment. The NRC staff will review whether this position is assigned other tasks that may prevent the timely performance of its assigned off-site dose assessment functions, as specified in the emergency plan. Alternatively, a licensee could demonstrate that installed automated systems or information technologies eliminate the need for an additional on-shift responder.
The NRC staff will consider whether the change basis adequately describes supportive features that promote timely, effective, and reliable off-site dose assessment (e.g., an automated computer program), and reliance upon installed and calibrated effluent monitors that would be available under accident conditions. Additionally, the automated systems or information technologies should be referenced in the emergency plan to ensure that future changes are reviewed using the RG 1.219 change process, as they were used as the basis for the proposed change.
Off-site Surveys / On-site (out-of-plant) / In-Plant Surveys
Table B-1 of NUREG-0654 assigns the major tasks of Offsite Surveys, Onsite (out-of-plant),
[and] In-plant surveys to HP [Health Physics] Technicians, with one technician on shift to perform in-plant surveys, and four more technicians available within 30 minutes. To adequately support an extension in the response time for the two 30-minute responders for on-site (out-of-plant) and in-plant surveys to 60 minutes, the licensee should show that the on-shift HP
staffing includes one HP technician per unit for a multi-unit site (i.e., a total on shift of two HP
technicians for a two unit site, or three HP technicians for a three unit site, etc.), or a minimum of two HP technicians on shift for a single unit site. A licensee could show that other on-shift positons have the training and qualifications needed to perform on-site surveys, and demonstrate that the survey results supplied by these positions would be sufficient to support initial emergency response actions until augmented by additional HP technicians. To adequately support an extension in the response time for the two 30-minute responders for off-site surveys, the licensee should show that on-shift methods can generate off-site dose projections. Additionally, NRC staff will consider the justification and whether it details features that promote timely and effective performance (e.g., an automated computer program), and reliance upon installed and calibrated plant effluent monitors that would be available under accident conditions.
Licensees may consider alternative approaches for staffing this functional area by training non-HP personnel to perform these tasks. An example of this alternative approach is provided in the guidance in ANSI/ANS 3.8.5-1992, Criteria for Emergency Radiological Field Monitoring, Sampling, and Analysis. This example provides criteria for emergency radiological field monitoring for training personnel assigned to perform radiological surveys. Training should be provided on the nature of the radiological hazards and associated effects that the survey team members are likely to encounter. Periodic retraining, as well as participation in drills and exercises, should also be specified as part of the training program. Job-specific training, both theoretical and hands-on, should be provided for all personnel assigned to radiological monitoring responsibilities. The training should include all phases of their emergency duties and the equipment that they may be required to operate to perform these duties. Task-qualified personnel assigned to these survey teams should follow the direction of fully qualified HP personnel, as discussed in NUREG/CR-5569, Health Physics Positions [HPPOS] Data Base, Revision 1,12 and HPPOS-238, Health Physics Position on Task Qualification of HP
Technicians.13
Technical Support
Table B-1 of NUREG-0654 assigns the major task of Technical Support to the Shift Technical Advisor on shift to perform core damage assessments and additional support with one individual within 30 minutes. To adequately support an elimination or extension of the one
30-minute technical support responder, the licensee should show that an on-shift position is identified as capable of initially filling the 30-minute responders role of Core/Thermal Hydraulics. Typically, this position will be the shift technical advisor. The licensee should show that this position has the necessary expertise with core/thermal hydraulics, and possesses the ability to offer adequate functional oversight to assess core conditions. The licensee should also show that the augmenting staff with core/thermal hydraulics expertise will be available within an appropriate time frame. NRC staff will review whether the justification identifies procedure and information technology advances since the implementation of NUREG-0654 such as improvements that allow using a symptom-based emergency operating procedure network, and computerized or automated systems for the acquisition and display of parameters used to evaluate core conditions.
Repair and Corrective Actions
Table B-1 of NUREG-0654 specifies that the major task of Repair and Corrective Actions are performed by two on-shift personnel with a note that this task may be provided by shift personnel assigned other functions. The Position Title or Expertise for these on-shift positions are Mechanical Maintenance and Electrical Maintenance. In addition, Table B-1 guidance specifies the addition of one electrical maintenance and one instrumentation and control technician within 30 minutes. To adequately support the elimination or extension of the two 30-minute responders, the licensee should show that on-shift positions are identified as capable of filling these roles. The justification for this staffing change should establish that the scope of repair and corrective actions performed by on-shift personnel would typically be limited to actions that promptly restore a non-functional component or system to functional status (e.g.,
resetting a relay or logic manipulation) or place a component or system in a desired configuration such as opening a valve or closing a breaker. The licensee should describe the training and qualifications provided to the assigned positions that would allow them to perform these actions. NRC staff will consider whether the licensee has identified any site-specific tasks that these personnel need to perform to ensure expected execution of emergency operating procedures or operation of plant safety equipment (e.g., support for operation of emergency core cooling system equipment). The justification basis should clearly state that expected repair and corrective actions would not include activities requiring work planning or implementation of lockout or tag-out controls to complete. The NRC staff will also review that the request indicates that there will not be any conflict between the added collateral duties and other assigned emergency response functions.
12 ADAMS Accession No. ML093220108.
13 http://www.nrc.gov/about-nrc/radiation/protects-you/hppos/hppos238.html Radiation Protection
Radiation protection personnel perform multiple roles during normal and emergency plant operations. These roles include access control, personnel monitoring, dosimetry, and HP
coverage for repair and corrective actions, search and rescue, first aid, and firefighting during emergency response operations. Guidance in Table B-1 of NUREG-0654 identifies two augmented responders at 30 minutes for the major task of Radiation Protection. To adequately support an extension in response timing of the two radiation protection 30-minute responders, the licensee should show that the on-shift HP staffing includes one HP technician per unit for a multi-unit site (i.e., a total on shift of two HP technicians for a two unit site or three HP technicians for a three unit site, etc.), or a minimum of two HP technicians for a single unit site on shift. Additionally, the licensee should demonstrate that on-shift HP technicians will be relieved of the need to perform access control, personnel monitoring, and dosimetry-related tasks, thereby freeing these personnel to cover vital response activities such as HP coverage for repair and corrective actions, search and rescue, first aid, and firefighting. The licensee could show that the basis for the justification includes the availability of installed area, process, airborne and effluent radiation monitors, automated systems and information technology solutions, and enhanced work processes that would be available under accident conditions.
Supporting tools and processes that may be considered include portal monitors, self-alarming dosimeters, and automated access control system for the radiologically controlled area (RCA)
that maintain active radiation work permits, which are readily available if an emergency is declared (e.g., the system verifies qualifications, dose margins, and access requirements).
Personnel assigned to perform this function should be fully qualified HP technicians as described in ANSI/ANS-3.1-1993, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, that was approved for use by Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear Power Plants.14 Personnel who are typically trained to a level of meter qualified to perform basic HP duties are not trained or do not have the necessary experience to perform complex HP duties, as discussed in HPPOS-0238, that would be necessary in a radiological emergency. For example:
(1) Typically the training does not include providing HP coverage for other personnel.
(2) Radiation protection is not normally incorporated into normal job duties.
(3) Radiological conditions during an emergency may be unknown or rapidly changing.
The following Emergency Plan functions would constitute in-plant protective actions, which would require a fully qualified HP technician:
Provide guidance for personnel protection to assist in minimizing personnel exposure.
Provide guidance for exposure authorizations, dose guidelines, and post-exposure assessments.
Provide job coverage for in-plant repair and corrective actions, and operations support, under changing radiological conditions.
Provide guidance for emergency decontamination of personnel, equipment, and facilities.
Provide guidance for personnel contamination control and respiratory protection.
14 ADAMS Accession No. ML003706932. Considerations of the Review Process for Proposed Extensions of NUREG-0654, Table B-1 - 60-Minute ERO Augmentation Times to 90 Minutes
Notification and Communication
To adequately support the elimination or extension of the two 60-minute responders, the licensee should show that two on-shift positions are identified to fill the 60-minute responders role to Notify licensee, State, local and Federal personnel [and] maintain communication. The licensee should show that these positions are not assigned other tasks that may prevent the timely performance of their assigned notification or communication functions, as specified in the emergency plan. The licensee should discuss how communication technologies employed by the proposed on-shift staff will support timely, effective, and reliable notifications. Additionally, the communications technologies should be referenced in the emergency plan to ensure that future changes are reviewed using the RG 1.219 change process, as they were used as the basis for the proposed change.
Emergency Operations Facility Director
Per the guidance in NUREG-0654, Table B-1, an augmented Senior Manager should fulfill the Emergency Operations Facility Director major task at 60 minutes. A licensee requesting a change in staff augmentation requirements that would have the lead manager unavailable to assume command and control within 60 minutes of the initial emergency declaration should show that the on-shift staff includes enough qualified supervision such that one supervisor will assume the emergency director role. The licensee should show that the on-shift supervisor performing the manager actions will not have any additional duties (e.g., each unit under the direction of a unit supervisor, a shift manager providing oversight of the plant response, and a designated emergency director responsible for emergency plan implementation).
Off-site Surveys / On-site (out-of-plant) / In-Plant Surveys
Per the guidance of NUREG-0654, Table B-1, there should be four augmented responders at 60
minutestwo for off-site surveys, one for on-site surveys, and one for in-plant surveys. To adequately support an extension of these responders to 90 minutes, the licensee should show that the on-shift HP staffing includes a minimum of four HP technicians in total for the site. The licensee should demonstrate that two HP technicians, in excess of the number evaluated previously for extending the 30-minute responders, are available for in-plant protective actions for the other maintenance personnel that need to be added to the on-shift staffing to compensate for the extension in augmentation time for the major task of Repair and Corrective Actions, and to perform surveys to assess any off-site release of radioactive materials.
Licensees may consider alternative approaches for staffing this functional area by training non-HP personnel to perform these survey tasks. See guidance provided above under Considerations of the Review Process for Proposed Extensions of NUREG-0654, Table B-1
30-Minute ERO Augmentation Times to 60 Minutes.
Chemistry/Radio-chemistry
Per the guidance of NUREG-0654, Table B-1, there should be one augmented Rad/Chem Technician at 60 minutes. To adequately support an extension of this responder beyond 60
minutes, the licensee should demonstrate that no chemistry-related task is required to be performed within 90 minutes of an emergency declaration (i.e., a task that is necessary for implementation of emergency operating procedures or operation of safety-related equipment),
or that all such tasks can be performed by the on-shift chemistry technician with no collateral duty concerns.
Technical Support
Per the guidance of NUREG-0654, Table B-1, Electrical and Mechanical expertise should be provided by two 60-minute responders under the Technical Support major task. To adequately justify an extension of these responders, the licensee should show that on-shift positions are capable of filling these roles during the 90-minute period after an emergency declaration. This will require a review of site procedures to identify the technical support tasks requiring electrical and mechanical expertise that must be performed within the first 90 minutes of an emergency. The licensee should then show that there are on-shift positions with the necessary expertise to perform the identified technical support functions, and that such performance will not prevent the timely performance of their other assigned functions, as specified in the emergency plan. The justification should identify procedure, training and information technology advances made since the implementation of NUREG-0654 that facilitate technical support assessments by on-shift personnel or obviate the need for such assessments within 90 minutes of an emergency declaration. Additionally, the change justification should address the ability of on-shift positions to perform troubleshooting activities without interfering with their primary emergency response duties (e.g., on-shift electrical or mechanical maintenance personnel with supervisory personnel to provide oversight).
Repair and Corrective Actions
Table B-1 of NUREG-0654 calls for the addition of one Mechanical Maintenance, one Rad Waste Operator, and an added Electrical Maintenance person within 60 minutes. 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. Additionally, as part of the justification for an extension request, the licensee should show that a radiological waste operator is not needed for the period of time to 90
minutes.
Radiation Protection
Radiation protection personnel perform multiple roles during normal and emergency plant operations. These roles include access control, personnel monitoring, and dosimetry, in addition to HP coverage for repair and corrective actions, search and rescue, first aid, and firefighting during emergency response operations. Per the guidance in Table B-1 of NUREG-0654, there should be two augmented responders at 60 minutes for the major task of Radiation Protection. To adequately support an extension in response timing of the two radiation protection 60-minute responders to 90 minutes, the licensee should show that the on-shift HP staffing includes as a minimum, four HP technicians in total for the site. The extra HP technicians are needed for in-plant protective actions for the other personnel added to the on-shift staffing to compensate for the extension in augmentation time, and to assess any off-site releases of radioactive materials. Additionally, the licensee request should demonstrate that on-shift HP technicians will be relieved of the need to perform access control, personnel monitoring, and dosimetry-related tasks, thereby freeing these personnel to cover vital response activities (e.g., HP coverage for repair and corrective actions, search and rescue, first aid, and firefighting). NRC staff will consider whether the basis for the justification includes the availability of installed area, process, airborne and effluent radiation monitors, automated systems and information technology solutions, and enhanced work processes. The licensee should include supporting tools and processes that will be considered such as portal monitors, self-alarming dosimeters, and automated access control systems for the RCA that maintain active radiation work permits that are readily available if an emergency is declared (e.g., the system verifies qualifications, dose margins, and access requirement). See guidance provided above under Considerations of the Review Process for Proposed Extensions of NUREG-0654, Table B-1 - 30-Minute ERO Augmentation Times to 60 Minutes.
Evaluation of Impact on Off-site Radiological Emergency Preparedness (REP) Plans
Any change in ERO on-shift or augmentation staffing levels and response times should be evaluated for impact on the FEMA approved off-site REP plans. Changes potentially affecting off-site REP plans should be discussed with respective State and/or local emergency management officials. The licensees LAR submittal should provide documentation of this assessment and concurrence of proposed change(s) potentially impacting off-site REP plans.
The documentation will be forwarded by NRC staff to FEMA to verify continued adequacy of off-site plans and preparedness.
BACKFITTING AND ISSUE FINALITY DISCUSSION
This RIS provides licensees with guidance on the scope and detail of information that should be provided in license amendment applications concerning changes to emergency response organization staffing and arrival times. This guidance does not represent new or changed staff positions. In addition, this RIS does not require any action or written response on the part of any licensee. Accordingly, issuance of this RIS in final form would not represent backfitting as defined in 10 CFR 50.109(a)(1), or be inconsistent with any applicable issue finality provision in
10 CFR Part 52. Therefore, the NRC did not prepare a backfit analysis for this RIS or further address the issue finality criteria in Part 52.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was published in the Federal Register
(81 Federal Register 13849) on March 15, 2016. Comments were received from three commenters. The staff considered all comments that were received. The evaluation of these comments, and the resulting changes to the RIS are discussed in a publicly available memorandum.15
CONGRESSIONAL REVIEW ACT
This RIS is a rule as defined in the Congressional Review Act (5 U.S.C. §§ 801-808). However, the Office of Management and Budget has not found it to be a major rule as defined in the Congressional Review Act.
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain new or amended information collection requirements that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing requirements were approved by the Office of Management and Budget (OMB), approval number 3150-0011.
15 ADAMS Accession No. ML16124A001. Public Protection Notification
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a current valid OMB control number.
CONTACT
Please direct any questions about this matter to the technical contact listed below, or to the appropriate Office of Nuclear Reactor Regulation project manager.
/ra/
/ra/
Louise Lund, Director Michael C. Cheok, Director Division of Policy and Rulemaking Division of Construction Inspection Office of Nuclear Reactor Regulation and Operational Programs
Office of New Reactors
Technical Contact:
Mike Norris, Team Leader, NSIR/ORLOB
301-287-3754 e-mail: Michael.Norris@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under NRC Library/Document Collections.
- via email
TAC: MF7013 OFFICE
NSIR/DPR/ORLOB
QTE*
NSIR/DPR/ORLOB/BC*
NSIR/DPR/IRIB/BC*
NSIR/DPR/DD
NAME
MNorris JDougherty JAnderson RKahler KCoyne DATE
01/08/2016
10/28/2015
01/08/2016
11/12/2015
12/14/2015 OFFICE
NRR/DPR/PGCB/PM NRR/DORL/D*
NRR/PMDA*
OIS
OE*
NAME
TKeene ABoland LHill KBenney GGulla (for NHilton)
DATE
01/07/2016
01/11/2016
01/11/2016
01/21/2016
01/22/2016 OFFICE
NRR/DPR/LA
OGC*
NRR/DPR/LA
NRR/DPR/PM
OGC*
NAME
ELee HBenowitz ELee (ABaxter)
BHarris HBenowitz DATE
01/04/2016
02/24/2016
05/09/2016
05/25/2016
05/27/2016 OFFICE
NRR/DPR/PGCB/BC*
NRO/DCP/D
NRR/DPR/D
NAME
SStuchell MCheok LLund
DATE
07/18/2016
07/22/2016
08/05/2016