ML14121A282
| ML14121A282 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/01/2014 |
| From: | Mahesh Chawla Division of Operating Reactor Licensing |
| To: | Dotson B, Erickson J Entergy Nuclear Operations |
| References | |
| MF2321 | |
| Download: ML14121A282 (3) | |
Text
NRR-PMDAPEm Resource From: Chawla, Mahesh Sent: Thursday, May 01, 2014 11:14 AM To: DOTSON, BARBARA E (bdotson@entergy.com); ERICKSON, JEFFREY S (JERICKS@entergy.com)
Cc: Johnson, Don; Norris, Michael; Anderson, Joseph; Carlson, Robert; Wengert, Thomas; Hoffman, Raymond; Duncan, Eric; Garmoe, Alex; Scarbeary, April; Lennartz, Jay
Subject:
Request for Additional Information - Palisades - LAR to Revise Emergency Response Response Organization Staff Augmentation Response Times - MF2321 By letter dated June 25, 2013, (Agency-wide Documents Access and Management System (ADAMS)
Accession No. ML13176A405) and supplemented by letters dated August 7, 2013, (ADAMS Accession No. ML13220A008) and February 13, 2014, (ADAMS Accession No. ML14044A059). Entergy Nuclear Operations, Inc. (ENO) requested an amendment to the Site Emergency Plan (SEP) for the Palisades Nuclear Plant (PNP).
PNP requests review and approval of a revision to the PNP SEP to increase the Emergency Response Organization (ERO ) augmentation response times for applicable ERO positions to go from 30-minutes to 60-minutes response times 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, and February 13, 2014, 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. ML13176A405)
- Reference 2: ENO letter dated August 7, 2013 (ADAMS Accession No. ML13220A008)
- Reference 3: ENO letter dated February 13, 2014 (ADAMS Accession No. ML14044A059)
- Reference 4: NEI 10-05, Revision 0, (ADAMS Accession No. ML111751698)
- Reference 5: NSIR/DPR ISG-01, (ADAMS Accession No. ML113010523)
- 1. It is not clear to the staff how NEI 10-05 (Reference 4) can be used to justify staff augmentation changes.
NEI 10-05 was created by the industry to help licensees fulfill the requirements of 10 CFR Appendix E, IV.A.9, which states, in part, 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. NEI 10-05 does not provide guidance that can be used to justify extensions to emergency response organization (ERO) timing nor does it assist the staff in making a reasonable assurance finding in accordance with 10 CFR 50.47(a) when evaluating the impact the possible delays in augmentation that may/or may not have with the ability of the on-shift crew to mitigate and/or manage the event.
- a. Section 3.0, Background of Reference 3 states: The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnel arrive in accordance with the sites emergency plan commitments. The augmenting ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus more fully on plant operations. NUREG-0654 guidance recommends that there be, in addition to on-shift personnel, 30 and 60-minute responders.
- i. Please provide additional justification that increasing the augmentation time from 30 minutes to 60 minutes for the applicable ERO responders will not negatively impact the ability of the on-1
shift crew to mitigate the event, i.e., the impact maintaining a dual-focus (plant and emergency preparedness (EP)) will have on public health and safety. For some positions, maintaining situational awareness of the changing plant conditions may become difficult when managing EP requirements for an extended period of time, particularly in the radiation protection area, oversight, and communications areas. For all positions where an extension of the augmentation time is proposed, provide justification to support the change(s). Please note that NEI 10-05 does not provide guidance relative to this area.
- 1. The specific tasks/positions to be evaluated are notifications/communications, offsite surveys, offsite dose assessment, onsite surveys, in-plant surveys, core/thermal hydraulics, health physics (HP) technician, electrician, and IC technician.
- 2. Please explain how the Operations Support Center (OSC), Emergency Operations Facility (EOF), and Joint Information Center (JIC) are staffed and provide discussion at to why the minimum staffing positions are not discussed as part of the applications minimum ERO staff.
- 3. The response to RAI #6, from Reference 3 did not provide sufficient information for the staffs review with respect to the original question. Please explain how the preset dose/dose rate area radiation monitor (ARM) alarms change from normal to accident range(s).
- 4. The response to RAI #8, from Reference 3 did not provide sufficient information for the staffs review with respect to the original question. As stated in #1 above, NEI 10-05 does not provide sufficient guidance that can be used as justification for ERO augmentation timing extensions. Please provide additional information that would document how operator training (LOR) and/or EP drills/exercises is sufficient to demonstrate that the Shift Manager can maintain situational awareness of the event, while performing all the EP functions assigned, for 60-minutes without assistance or relief. In particular, the general emergency (GE) scenario typically requires a significant amount of time communicating with State and local agencies, as well as the NRC. Please provide documentation that the stated training programs use this scenario, with significant multiple communication demands, for 60-minutes.
- 5. From Reference 3, Attachment 3, B.9: The GE event is intended to be a loss of all three fission product barriers with a release in progress > 1 Rem total effective dose equivalent (TEDE) offsite. Please revise accordingly or provided additional justification.
- 6. From Reference 3, Attachment 3, V.A.20: For the release start time, it is the staffs expectations that it begins with the start of the event, not after 15-minutes as stated. Please revise accordingly or provided additional justification.
If needed, please arrange a teleconference to discuss the above request with the NRC staff. Thanks Mahesh Chawla Project Manager Phone: 301-415-8371 Fax: 301-415-1222 mahesh.chawla@nrc.gov 2
Hearing Identifier: NRR_PMDA Email Number: 1263 Mail Envelope Properties (Mahesh.Chawla@nrc.gov20140501111400)
Subject:
Request for Additional Information - Palisades - LAR to Revise Emergency Response Response Organization Staff Augmentation Response Times - MF2321 Sent Date: 5/1/2014 11:14:16 AM Received Date: 5/1/2014 11:14:00 AM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:
"Johnson, Don" <Don.Johnson@nrc.gov>
Tracking Status: None "Norris, Michael" <Michael.Norris@nrc.gov>
Tracking Status: None "Anderson, Joseph" <Joseph.Anderson@nrc.gov>
Tracking Status: None "Carlson, Robert" <Robert.Carlson@nrc.gov>
Tracking Status: None "Wengert, Thomas" <Thomas.Wengert@nrc.gov>
Tracking Status: None "Hoffman, Raymond" <Raymond.Hoffman@nrc.gov>
Tracking Status: None "Duncan, Eric" <Eric.Duncan@nrc.gov>
Tracking Status: None "Garmoe, Alex" <Alex.Garmoe@nrc.gov>
Tracking Status: None "Scarbeary, April" <April.Scarbeary@nrc.gov>
Tracking Status: None "Lennartz, Jay" <Jay.Lennartz@nrc.gov>
Tracking Status: None "DOTSON, BARBARA E (bdotson@entergy.com)" <bdotson@entergy.com>
Tracking Status: None "ERICKSON, JEFFREY S (JERICKS@entergy.com)" <JERICKS@entergy.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 6696 5/1/2014 11:14:00 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received: