ML18214A422

EP SDP Comment Form ANS Improvement

ML18214A422
Person / Time
Site:	Harris
Issue date:	07/31/2018
From:	Yarley C Duke Energy Progress
To:	Raymond Gibson Policy and Oversight Branch
References
Download: ML18214A422 (1)

Text

FOCUSED SELF-ASSESSMENT:

EMERGENCY PREPAREDNESS SIGNIFICANCE DETERMINATION PROCESS STAKEHOLDER COMMENT FORM EP SDP FSA Comment Number: ____________________ (To be entered by NRC Staff)

Originator: Chuck Yarley Organization: Shearon Harris Regulatory Affairs Relevant Procedure(s): IMC 609 Appendix B, Emergency Preparedness SDP Applicable Section(s): Table 5.10-1, Entry (b)(5), Degraded RSPS FUNCTION table entry Please return to Ray Gibson at the following email: Raymond.Gibson@nrc.gov COMMENT:

In Table 5.10-1, under the entry for (b)(5), there is a Program Element for "Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway." Under the 'Degraded RSPS Function' column, there is an entry, "Loss of the primary method of alerting 100% of the population within 0-5 miles of the plant with the prearranged backup capability still available. (See Additional Guidance section regarding a planned ANS outage.)" Meeting this criteria would screen White.

The declaration above does not include an allowable time to the loss of ANS function. By the way the criteria is written, any primary ANS outage is instantly a White violation regardless of duration. This makes a loss of ANS more severe than the loss of any Emergency Response Facility, which can be out of service for up to seven days before a finding of significance is warranted.

PROPOSED RESOLUTION:

An ANS system outage should include guidance on outage timing similar to that of Emergency Response Facilities.

NRC RESPONSE:

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