ML13353A042
| ML13353A042 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/16/2013 |
| From: | Mahesh Chawla Division of Operating Reactor Licensing |
| To: | Erickson J Entergy Nuclear Palisades |
| References | |
| TAC MF2321 | |
| Download: ML13353A042 (10) | |
Text
NRR-PMDA-ECapture Resource From: Chawla, Mahesh Sent: Monday, December 16, 2013 3:08 PM To: ERICKSON, JEFFREY S (JERICKS@entergy.com)
Cc: Hoffman, Raymond; Johnson, Don; Norris, Michael; Carlson, Robert; Anderson, Joseph
Subject:
Request for Additional Information - Palisades - Proposed Revision to Palisades Site Emergency Plan (SEP) to increase the staff Augmentation response time for certain Emergency Response Organization (ERO) positions from 30 to 60 minutes - MF2321 Attachments: MF2321_RAIs_2.docx By letter dated June 25, 2013, (Agency-wide Documents Access and Management System (ADAMS)
Accession No. ML1317A405), Entergy Nuclear Operations, Inc. (ENO) requested an amendment to the Site Emergency Plan (SEP) for the Palisades Nuclear Plant (PNP). The staff requested a copy of the PNP On-Shift Staffing Analysis (OSA) Final Report to support the review of this license amendment, which was submitted via letter dated August 7, 2013 (ADAMS Accession No. ML13220A008).
ENO requests review and approval of a revision to the PNP SEP to increase the staff augmentation response times for all applicable Emergency Response Organization (ERO) positions to go from 30-minutes to 60-minutes response time between event declaration and relief of applicable emergency response functions from the PNP on-shift staff.
The attached requests for additional information (RAIs) are necessary to facilitate the technical review being conducted by the NRCs Division of Preparedness and Response, Operating Reactor Licensing and Outreach Branch staff. Please provide the docketed response to these RAIs within 60 days of the receipt of this email. Please arrange a teleconference with the NRC staff to discuss these RAIs to ensure the quality and the timely response. Thanks Mahesh Chawla Project Manager Phone: 3014158371 Fax: 3014151222 mahesh.chawla@nrc.gov 1
DRAFT REQUEST FOR ADDITIONAL INFORMATION PALISADES NUCLEAR PLANT LICENSE AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGE DOCKET NO. 50-255 TAC No.s By letter dated June 25, 2013, (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML1317A405), Entergy Nuclear Operations, Inc. (ENO) requested an amendment to the Site Emergency Plan (SEP) for the Palisades Nuclear Plant (PNP). The staff requested a copy of the PNP On-Shift Staffing Analysis (OSA) Final Report to support the review of this license amendment, which was submitted via letter dated August 7, 2013 (ADAMS Accession No. ML13220A008).
ENO requests review and approval of a revision to the PNP SEP to increase the staff augmentation response times for all applicable Emergency Response Organization (ERO) positions to go from 30-minutes to 60-minutes response time between event declaration and relief of applicable emergency response functions from the PNP on-shift staff.
The following requests for additional information (RAIs) are necessary to facilitate the technical review being conducted by the Division of Preparedness and Response, Operating Reactor Licensing and Outreach Branch staff. Timely and accurate response to these draft RAIs is requested.
The following RAIs are based upon information provided in ENO letters dated June 25 and August 7, 2013, as well as from NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Revision 0, (ADAMS Accession No. ML111751698) and the Interim Staff Guidance, Emergency Planning for Nuclear Power Plants, (NSIR/DPR-ISG-01), (ADAMS Accession No. ML13010523). For ease of use, each RAI will reference the applicable document as follows:
Reference 1: ENO letter dated June 25, 2013 (ADAMS Accession No. ML1317A405).
Reference 2: ENO letter dated August 7, 2013 (ADAMS Accession No. ML13220A008).
Reference 3: NEI 10-05, Revision 0, (ADAMS Accession No. ML111751698).
Reference 4: NSIR/DPR ISG-01, (ADAMS Accession No. ML113010523)
- 1. Section 4.2.4.2 of Reference 1 states that the on-shift Chemistry Technician is not required to perform any chemistry/radiochemistry sampling within the first 90-minutes of an analyzed event. Please explain how the reactor coolant sampling related emergency action levels (EALs) are determined for events that result in a loss of all three fission product barriers with no advance warning as required by section 2.10 of Reference 3. In addition, section 4.2.4.2 also states that the on-shift Chemistry Technician can perform offsite dose assessment calculations, including backup
methodologies. Please provide evidence to support the qualifications of the on-shift Chemistry Technician to perform the normal and backup methods of offsite dose assessment calculations.
- 2. Section 4.2.4.4 of Reference 1 states that in-plant radiological monitoring instrumentation is sufficient for monitoring radiological conditions in the plant thus reducing the need for radiation protection (RP) personnel to enter the plant to obtain radiological data. Please explain how on-shift staff are made knowledgeable of area radiation levels in unknown and potentially escalating radioactive environments for events that result in an immediate loss of all three fission product barriers, which may potentially cause in-plant radiological instrumentation to be off-scale.
- 3. Section 4.2.5.1 of Reference 1 justifies the increase in response time for the Shift Engineer/Shift Technical Advisor (STA) by the addition of an on-shift Communicator.
Please explain how the addition of an on-shift Communicator justifies the increase in response time for the core/thermal hydraulic technical support function, which is not related to the need for communications.
- 4. Section 4.2.5.2 of Reference 1 states that during the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. While the staff agrees with this statement, the repair and/or corrective action(s) needed during the most significant events are related to issues with the emergency core cooling system (ECCS) not operating correctly. Please elaborate as to how the Nuclear Plant Operators can perform action(s) typically assigned to qualified maintenance personnel for all reasonable failure modes of ECCS equipment, including logic manipulation. Please provide documentation that supports this analysis and supports the task(s) that the Nuclear Plant Operators may need to do, and the qualifications needed to perform them.
- 5. Section 4.2.6.1 of Reference 1 provides an analysis of the PNP automated radiation work permit system but does not discuss how this automated system would work during accident conditions, particularly those with extensive radioactive environments and changing plant conditions. Is the system automation capable of adjusting dose margins when entry is required during the most egregious accident scenarios, i.e., an immediate loss of all three fission product barriers? If RP involvement is necessary, please provide an evaluation of the impact on the on-shift RP Technician.
- 6. Section 4.2.6.2 of Reference 1 provides justification for changing the RP Technician response time that includes the use of installed area radiation monitoring (ARMs) alarming at preset dose and dose rates. Please explain how these ARMs will suffice for events that are based upon an immediate loss of all three fission product barriers and thus may introduce dose or dose rates significantly greater than the alarm setpoints and/or the scale of the ARMs.
- 7.Section II of Reference 2 states that the accident scenario of a main control room fire and shutdown at the remote shutdown panel is the most limiting. The staff believes that the accident scenario related to 10 CFR 50.54(hh)(1), involving potential or actual aircraft attacks could potentially be the accident scenario which would require the most use of available on-shift staff, particular those who would be assigned fire
brigade duties or tasked with manipulating plant equipment in preparation for the potential attack. Please provide more justification that supports this decision.
- 8.Section II.C of Reference 2 justifies adding the responsibility of some site specific event notifications to the Shift Manager by stating that they are of a limited duration and does not require a time motion study (TMS) or analysis to justify it. While individual ERO functions of limited duration may be added without needing a TMS to justify it, the number of ERO functions assigned to the Shift Manager may be extra burdens that could affect the timeliness of emergency response actions. Please justify how these extra functions would not affect the timeliness of the Shift Managers responsibilities.
- 9.Section II.C of Reference 2 states that an analysis, or TMS, is not needed to support the addition of communicator duties to a Nuclear Plant Operator, RP Technician, or Chemistry Technician, for a 10 CFR 50.54(hh) event. Please provide further technical discussions for this statement as the staff cannot determine what duties are assigned to these positions for this accident scenario.
- 10.Section IV.C.2, and Appendix A (Event # 14), of Reference 2 states that no emergency declaration would be expected for a dropped spent fuel cask. Please explain when EAL E-HU1 would be declared and provide further explanations as appropriate.
- 11. Reference 2, Appendix B, Event #1, Design Basis Threat (DBT):
- a. Please explain why a water-based threat was not analyzed, do not use sensitive or safeguard information to respond..
- b. In accordance with the direction given in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the emergency classification level (ECL) ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- c. Please explain the basis for why the STA was not analyzed to justify the responsibility of performing notification to the NRC of the DBT event.
- d. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- e. Reference 4, section IV.C (page 14) states that licensees should ensure that sufficient staff is available to simultaneously implement both the emergency plan and the security plan in a DBT environment to include, as a minimum, the potential for restricted movement of site personnel.
The staff can find no evidence of this being reviewed, please review and provide further information to support the justification.
- 12. Reference 2, Appendix B, Event #2, Control Rod Ejection Accident:
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- 13. Reference 2, Appendix B, Event #3, Small Line Break Outside Containment:
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- 14. Reference 2, Appendix B, Event #4, Main Steam Line Break Inside Containment:
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- 15. Reference 2, Appendix B, Event #5, Loss of Coolant Accident:
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- 16. Reference 2, Appendix B, Event #6, Fuel Handling Accident;
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- 17. Reference 2, Appendix B, Event #7, Waste Tank Rupture:
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- 18. Reference 2, Appendix B, Event #8, Aircraft Probable Threat:
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- c. The guidance in Reference 3, specifically Section 2.13, requires a site-specific list of response tasks for this event, and a collateral duty analysis (with possible TMS) to verify personnel are not assigned ERO functions that would preclude timely performance of their other assigned functions.
As stated in the assumptions for this event in Reference 2, consideration of the dispersal of the site fire brigade away from target areas must be given, note that Table 3 appears to be inconsistent with this assumption.
Please follow the guidance provided in Section 2.13 of Reference 3 and revise accordnigly.
- 19. Reference 2, Appendix B, Event #9, Control Room Fire Requiring Evacuation and Remote Shutdown:
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- c. In accordance with Section 2.9 of Reference 3, please provide the validation results for the assessment and determination that this event scenario is the most limiting fire related scenario.
- 20. Reference 2, Appendix B, Event #10, Station Blackout:
- a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- 21. Reference 2, Appendix B, Event #11, LOCA/General Emergency with Release and PAR:
- a. Please explain why the accident assumption is made that this event would be prefaced by the declaration of a Site Area Emergency (SAE),
and thus all actions for the SAE are completed. Reference 3, Section 2.10, and Reference 4,Section IV.C, do not make this assumption. This event is based upon an immediate loss of all three fission product barriers with an offsite release, regardless of cause, and expects the on-shift organization to be able to effectively implement the emergency plan until relieved by the ERO staff, as paraphrased from Reference 3, 2.10, and Reference 4,Section IV.C. Please explain.
- b. In accordance with the guidance given in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve offsite protective action recommendations iii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iv. Approve extension to allowable dose
- v. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
vi. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vii. Complete NRC event notification form viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- c. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.
- 22. Reference 2, Appendix B, Event #15, Steam Tube Rupture with Concurrent Loss of Off-Site Power:
- a. In accordance with the guidance given in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:
- i. Declare the ECL ii. Approve content of State/Local notifications
- 1. Who completes this content? This is not listed in the OSA and was not analyzed.
iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
iv. ERO notification
- v. Complete State/Local notification form
- 1. Inconsistent with ii above, please explain.
vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)
- b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.