L-19-166, Response to Request for Additional Information and Supplemental Information Regarding License Amendment Request for Proposed Post-Shutdown Emergency Plan

Response to Request for Additional Information and Supplemental Information Regarding License Amendment Request for Proposed Post-Shutdown Emergency Plan

ML19189A109
Person / Time
Site:	Davis Besse
Issue date:	07/08/2019
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2019-LLA-0011, L-19-166
Download: ML19189A109 (9)

Text

FENOC ~

5501 North State Route 2 FirstEnergy Nuclear Operating Com{J811y Oak Harbor, Ohio 43449 Mark B. Bezilla 419-321-7676 Vice President - Nuclear Fax: 419-321-7582 July 8, 2019 L-19-166 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Response to Request for Additional Information and Supplemental Information Regarding License Amendment Request for Proposed Post-Shutdown Emergency Plan (EPID L-2019-LLA-0011)

By application dated February 5, 2019 (Accession No. ML19036A524), as supplemented by letter dated April 10, 2019 (Accession No. ML19100A000),

FirstEnergy Nuclear Operating Company (FENOC) submitted a license amendment request for Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). The proposed amendment would revise the Davis-Besse emergency plan for the post-shutdown and permanently defueled condition.

On June 13, 2019, the Nuclear Regulatory Commission (NRC) staff requested additional information to complete its review. The FENOC response is contained in Attachment 1. As a result of the FENOC response, Attachment 2 contains updates to the Proposed Post-Shutdown Emergency Plan.

There are no regulatory commitments included in this submittal. If there are any questions, or if additional information is required, please contact Mr. Thomas Lentz, Manager, FENOC Nuclear Licensing and Regulatory Affairs, at (330) 315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July .../3_, 2019.

f!JU 1')

Sincerely, ,/l._1P

/J tdti _.1. ?//

f Mark B. Bezilla

Davis-Besse Nuclear Power Station, Unit No. 1 L-19-166 Page 2 Attachments:

1. Response to Request for Additional Information

2. Updated Proposed Post-Shutdown Emergency Plan cc: NRC Regional Administrator - Region Ill NRC Resident Inspector NRC Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

Attachment 1 L-19-166 Response to Request for Additional Information Page 1 of 2 The NRC staff's request for additional information is provided in bold text followed by the FENOC response.

Request for Additional Information (RAI) 1 The Technical Support Center (TSC) Engineering Manager is the only minimum staffing position required for TSC activation which will be retained with this proposed change. Section 5.4.1.b. "Technical Support Center (TSC)," of the proposed post-shutdown emergency plan (PSEP) states, in part:

TSC staff will assess facility conditions, and provide management and technical assistance to the Control Room, as required, to mitigate the effects of the emergency event. The TSC staff will analyze and track parameters relating to the technical [emergency action levels] EALs, and will advise the Emergency Director of the need to reclassify the emergency.

Section 7.2.1, "Technical Support Center (TSC)," of the proposed PSEP states:

"The TSC serves as the workplace for key [emergency response organization]

personnel who, during emergencies, assist the Control Room staff, perform accident assessment, and determine appropriate protective actions."

Explain how the TSC Engineering Manager can provide management and technical support to the control room personnel during emergency conditions without support from other TSC personnel.

Response

As shown on Tables 2.4-1 and 4.5-2 of the Post-Shutdown Emergency Plan (PSEP)

License Amendment Request (LAR), in addition to the TSC Engineering Manager, other augmented positions will respond to the TSC following an emergency declaration.

When the TSC is staffed with the TSC Engineering Manager, the Emergency Plant Manager, the Emergency Assistant Plant Manager (who may report either to the control room or the TSC), and the Emergency RP Manager, the capability exists to assess facility conditions, provide management and technical support to the control room, and mitigate the effects of the emergency.

Table 5-1. B of the Proposed Post-Shutdown Emergency Plan, which was included in the LAR, identified the TSC Engineering Manager and the Emergency Assistant Plant Manager as positions that respond upon declaration of an Alert or higher emergency classification. To ensure the TSC minimum staff can provide management and L-19-166 Page 2 of 2 technical support, the Proposed Post-Shutdown Emergency Plan is revised, as provided in Attachment 2, to add the Emergency Plant Manager and the Emergency RP Manager as minimum staff required for TSC activation with the facility in the permanently shutdown and defueled condition.

RAI 2

Currently, Table 5-1.8 of the emergency plan lists the NRC Liaison as required minimum staff for an alert or higher emergency classification. LAR Section 4.5.2.3, "Emergency Operations Facility Augmenting Positions," states, in part:

The proposed staffing changes includes the elimination of the NRC Liaison position. The primary duty of the NRC Liaison is to establish and maintain communication with the NRC. The Technical Liaison -

EOF [Emergency Operations Facility] Communicator, located in the EOF, is assigned these duties in the post-shutdown emergency plan.

However, the Technical Liaison - EOF Communicator is not listed as minimum staff in the proposed revision to Table 5-1.8.

Explain why the Technical Liaison - EOF Communicator does not need to be a required minimum staff position given that this position will assume the duties of the NRC Liaison. Explain why the current basis for including the NRC Liaison as a minimum staff position is not valid for the permanently shutdown condition.

Response

Table 5-1.B of the Proposed Post-Shutdown Emergency Plan is revised, as provided in , to identify the Technical Liaison - EOF Communicator as minimum staff required for EOF activation with the facility in the permanently shutdown and defueled condition. Since the Technical Liaison - EOF Communicator is assuming the tasks of the NRC Liaison position and will be a minimum staffing position, the basis of the NRC Liaison being a minimum staffing will apply to the Technical Liaison - EOF Communicator.

Attachment 2 L-19-166 Updated Proposed Post-Shutdown Emergency Plan (Four pages follow)

Updated Mark-up Page of the Proposed Post-Shutdown Emergency Plan (One page follows)

5-36 DBNPS Post-Shutdown Emergency Plan Revision ~TBD TABLE 5-1 MANPOWER, LOCATION, AND RESPONSE CON SIDERA TIONS FOR EMERGENCIES Page 2 of2 B. AUGMENTED EMERGENCY RESPONSE STAFFING REQUIREMENTS ALERT, SITE AREA EMERGENCY, UNUSUAL EVENT GENERAL EMERGENCY PERSONNEL TIME PERSONNEL TIME CONTROL ROOM CONTROL ROOM fmergency Assistant Plant Manager (1)~ Alerted Emergency Assistant Plant Manager (1r Nonnal Hours:

30minutes Off Hours:

60 minutes QPERATIONS SUPPORT CENTER OPERATIONS SUPPORT QENTEB OSC Manager (1) Alerted OSCManager (1)

OSC RP Coordinator (1) OSC RP Coordinator (1) Normal Hours:

Mechanical Maintenance (21) 30 minutes I IA6tFUA'l8Rt & G8RtFGI&

Electrical Maintenance Add (2)

(~1)

Total Off Hours:

RP Technician (1) (2) 60minutes Chemi&t,y +8GRRieiaR EO} ~

RP Technician (3j) (iID 1-2 hours GheFRi&tf:'j ::i:eshRisiaA ~ ~

TECHNl~AL §UPPORT CENTER TECHNICAb SUPPQRT CENTER As Required:

TSC Engineering Manager (1) Alerted TSC Engineering Manager (1) Normal Hours:

CeF8/JheFmal MydFauliG EngiR88F (-11 30minute&

fimerg1mcx Plaal Menager ill Off Hours:

EmergenS:)! RP Manager ill 60minutes TSC l&C Engineer ~

TSC Electrical Engineer µ.} 1-2 hours TSC Mechanical Engineer fB Call inas necessarv EMERGENCY OPERATIONS FACILITY EMERGENCY OPERATIONS FACIUTY As Required:

Emergency Director (1) Alerted Emergency Offsite Manager {1) Normal Hours:

Emergency Offsite Manager (1) Dose Assessment Coordinator {1) 60minutes Emergency Planning Advisor (1) Off Hours:

60 minutes RMTs {3) 30-60 minutes Emergency Director (1)

I NRC btai&eATechnir;!!I Liaison - EOF Communicator State/County Communicator (1)

{1) 1-2 hours NOTES : I. All time requirements ere based on optimum response conditions.

2. Figure 5-2, Emergency Response Organization, depicts functional levels beyond these augmented staffing requirements.

3 The Emergency Assistant Plant Manager may respond to the TSC

Updated Clean Page of the Proposed Post-Shutdown Emergency Plan (One page follows)

5-36 DBNPS Post-Shutdown Emergency Plan Revision TBD TABLE 5-1 MANPOWER, LOCATION, AND RESPONSE CONSIDERATIONS FOR EMERGENCIES Page 2 of2 B. AUGMENTED EMERGENCY RESPONSE STAFFING REQUIREMENTS ALERT, SITE AREA EMERGENCY, UNUSUAL EVENT GENERAL EMERGENCY PERSONNEL TIME PERSONNEL TJME CONTROL ROOM CONTROL ROOM Emergency Assistant Plant Manager (1 )3 Alerted Emergency Assistant Plant Manager (1)3 Normal Hours:

30 minutes Off Hours:

60 minutes OPERATIONS ~UPPORT CENTER OPERATIONS SUPPORI CENTl;B OSC Manager (1 ) Alerted OSCManager (1) osc RP Coordinator (1} OSC RP Coordinator (1) Normal Hours:

Mechanical Maintenance (1) 30 minutes Electrical Maintenance (1)

Add Total Off Hours:

RP Technician (1) (2) 60 minutes RP Technician (1) (3) 1-2 hours TECHNICAL SUPPORT CENTE;:B TECl:fNl~AL ~uePORT CENTER As Required:

TSC Engineering Manager (1) Alerted TSC Engineering Manager (1) Nonnal Hours:

30 minutes Emergency Plant Manager (1) Off Hours:

Emergency RP Manager (1) 60 minutes TSC l&C Enginee, Call in as TSC Electrical Engineer 1-2 hours necessary TSC Mechanical Engineer EMERGENCY OPERATIO~S FAClblTY EMERGENCY Qf,RATION§ FACIU!X As Required:

Emergency Director (1) Alerted Emergency Offsite Manager (1) Normal Hours:

Emergency Offsite Manager (1) Dose Assessment Coordinator (1) 60 minutes Emergency Planning Advisor (1) Off Hours:

60minutes RMTs (3) 30-60 minutes Emergency Director (1)

Technical Liaison - EOF (1) 1-2 hours Communicator State/County Communicator (1)

NOTES: I. All time requirements are based on optimum response conditions.

2. Figure 5-2, Emergency Response Organization, depicts functional levels beyond these augmented staffing requirements.

3. The Emergency Assistant Plant Manager may respond to the TSC.