ML18214A421

EP SDP Comment Form Declaration Improvement

ML18214A421
Person / Time
Site:	Harris
Issue date:	07/31/2018
From:	Yarley C Duke Energy Progress
To:	Raymond Gibson Policy and Oversight Branch
References
Download: ML18214A421 (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)(4), 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)(4), there is a Program Element for "A standard scheme of emergency classification and action levels is in use." Under the 'Degraded RSPS Function' column, there is an entry, "An EAL [Emergency Action Level] has been rendered ineffective such that any General Emergency would not be declared for a particular off normal event, but because of other EALs, an appropriate declaration could be made in a degraded manner (e.g., delayed)."

Meeting this criteria would screen White.

A declaration is not considered "delayed" if it is made "within the 15-minute timeliness capability requirement." Thus, if an alternate EAL declaration is available to make the appropriate declaration, but the declaration occurs more than 15 minutes after meeting the criteria for the EAL found to be ineffective, the RSPS is degraded and screens to a significance of White.

Overall, the significance of this column entry screens needlessly high. The overall goal of Emergency Preparedness is to protect the health and safety of the public in a radiological emergency. To this end, EALs are designed to provide an emergency declaration with sufficient timeliness to ensure appropriate protective actions are issued in sufficient time to protect the public. If an alternate EAL would ensure an appropriate declaration, that declaration should allow sufficient time to protect the health and safety of the public, even if it is more than 15 minutes beyond the time the initial, ineffective EAL should have been declared for a particular event.

This would also be true for the 'Degraded RSPS Function' column entry, "The EAL classification process is not capable of classifying a General Emergency or a Site Area Emergency within 15 minutes or declaring the emergency promptly once the appropriate classification level is determined," as long as an alternate or redundant EAL were to remain available and were itself declared in a timely manner after criteria for the alternate EAL were met.

PROPOSED RESOLUTION:

Currently, an alternate or redundant EAL that can be made within 15 minutes of the time the ineffective EAL should be made will mitigate the significance of the finding, causing it to screen to green. We recommend increasing the credit for alternate or redundant EALs, so that if a alternate or redundant EAL exists, and can be declared within 15 minutes of the time the criteria of the alternate or redundant EAL is met for a given condition (as oppose to 15 minutes from the time of meeting the criteria of the ineffective EAL), that condition would also screen to green and would not be considered a degraded RSPS.

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