LIC-17-0036, Supplemental Response to Request for Additional Information - Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment
| ML17095A949 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  (DPR-040) |
| Issue date: | 04/05/2017 |
| From: | Fisher M Omaha Public Power District |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CAC MF8326, LIC-17-0036 | |
| Download: ML17095A949 (5) | |
Text
Omaha Public Power District LIC-17-0036 April 5, 2017 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285
Subject:
Supplemental Response to Request for Additional Information, Fort Calhoun Station, Unit No. 1 - Final Request for Additional Information Concerning Post-Shutdown EPian Amendment {CAC MF8326)
References:
- 1.
Letter from OPPD (S. M. Marik) to USNRC (Document Control Desk), "License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition," dated September 2, 2016 (LIC-16-0076)
- 2.
EMAIL from NRC (J. Kim) to OPPD (E. P. Matzke), "Fort Calhoun Station-Final Request for Additional Information Concerning Post-Shutdown EPian Amendment (CAC MF8326)", dated February 2, 2017 (ML17033A969)
- 3.
Letter from OPPD (Mary J. Fisher) to USNRC (Document Control Desk), "Response to Request for Additional Information, Fort Calhoun Station, Unit No. 1 - Final Request for Additional Information Concerning Post-Shutdown EPian Amendment (CAC MF8326),"
dated March 3, 2017 (LIC-17-0020) (ML17062A887)
By letter dated September 2, 2016 (Reference1 ), the Omaha Public Power District (OPPD) proposed an amendment to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station (FCS). The proposed amendment would revise the FCS Emergency Plan for the permanently defueled condition. Specifically, the proposed changes would revise the on-shift staffing and Emergency Response Organization (ERO) staffing levels.
On February 2, 2017 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the proposed emergency plan changes. By letter dated March 3, 2017 (Reference 3), OPPD provided responses to the RAI. Attachment 1 of this letter provides a supplemental response to the RAI.
444 SOUTH 16TH STREET MALL
- OMAHA, NE 68102-2247
U. S. Nuclear Regulatory Commission L1 C-17 -0036 Page2 This letter contains no regulatory commitments.
If you should have any questions regarding this submittal or require additional information, please contact Mr. Bradley H. Blome at (402) 533-7270.
Respectfully,
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Mary J. Fisher Senior Director Decommissioning Fort Calhoun Station MJF/epm
Attachment:
Supplemental Response to Request for Additional Information c:
K. M. Kennedy, NRC Regional Administrator, Region IV J. Kim, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska
L1 C-17 -0036 Attachment Page 1 ATTACHMENT SUPPLEMENTAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ADMENDMENT REQUEST FOR EMERGENCY PLAN CHANGE OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT N0.1 DOCKET NO. 50-285 By letter dated September 2, 2016 (Agencywide Documents Access and Management System (ADAMS} Accession No. ML16246A321), Omaha Public Power District (OPPD, the licensee), requested prior U.S. Nuclear Regulatory Commission (NRC) approval of an amendment to the Fort Calhoun Station (FCS) Radiological Emergency Response Plan (RERP) in support of OPPD's intent to permanently cease power operations at FCS no later than December 31,2016. The proposed amendment to the FCS RERP would revise the FCS Emergency Response Organization (ERO) on-shift and augmented staffing, based on NRC approval, based on the certifications for permanent cessation of power operations and permanent removal of fuel from the reactor vessel to the NRC in accordance with §50.82(a)(1)(i} and (ii) to Title 10 of the Code of Federal Regulations (10 CFR), which will no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.
The standards in §50.47 to Title 10 ofthe Code of Federal Regulations (10 CFR 50.47),
"Emergency plans," and the requirements of Appendix E to 10 CFR Part 50, "Emergency Planning and Preparedness for Production and Utilization and Production Facilities," on which the staff based its review, are as follows:
10 CFR 50.47(b}(1), states, in part:"... each principal response organization has staff to respond and to augment its initial response on a continuous basis;"
10 CFR 50.47(b)(2) states, in part:"... adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available... ;"
10 CFR Part 50, Appendix E,Section IV.A, states, in part: "The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization... ;" and 10 CFR Part 50, Appendix E,Section IV.C.1, states, in part: "The emergency classes defined shall include (1} Notification of unusual events, (2) alert, (3} site area emergency, and (4) general emergency.
The evaluation criteria, as applicable based on the permanently shutdown and defueled condition of the facility, contained in Section II.B (Onsite Emergency Organization) of NUREG-0654/FEMA-REP-1 1 Revision 1 1 "Criteria for Preparedness and Evaluation of Radiological Emergency Response Plans and Nuclear Power Plants," were used in evaluating proposed ERO staffing changes. The staff's technical review also takes into consideration that prior to the Commission's approval of requested exemptions to the standards in 10 CFR 50.47 and the requirements of Appendix E to 10 CFR Part 50, the proposed FCS RERP must continue to provide adequate on-shift and augmented ERO staffing to effectively respond to a radiological release escalating to a General Emergency classification and requiring consideration of offsite protective actions by State and local officials.
LIC-17-0036 Attachment Page2 The requests for additional information (RAI) listed below are necessary to facilitate the technical review being conducted by the Office of Nuclear Security and Incident Response/ Division of Preparedness and Response, Reactor Licensing Branch (NSIRIDPRIRLB). A timely and thorough response to these RAis is requested in order to meet the proposed deadline requested by the licensee.
RAI*FCS-1 Page 19 of Attachment 1, "Description and Evaluation of the Proposed Changes,"
identifies only one Radiation Protection (RP) Technician in the Operational Support Center (OSC) for elimination. However, pages 27 and 28 of Attachment 2, "Tabular Summary of Proposed Changes to the FCS RERP," identifies the following:
Before (Rev.1)
After (Pending Reason for Change Revision Number) 2 RP Technicians Deleted These positions have no defined tasks in procedures.
All offsite survey tasks are currently performed by the Field Team Technicians, which are maintained.
2 RP Technicians 1 RP Technician The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.
2 RP Technicians 1 RP Technician The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the _Qosition is reduced.
a) With respect to the proposed 2 RP Technicians being deleted above, what tasks do these RP Technicians actually perform in the current RERP and how would they be utilized for an event classified as a General Emergency with a radiological release requiring an offsite protective action recommendation (PAR) to be issued?
Please provide further justification for their elimination based on their current tasks.
Supplemental Response "a" In License Amendment Request (LAR) 16-02, dated September 2, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16246A321), Fort Calhoun Station (FCS) indicated that one or more training drills would be developed and conducted prior to implementation of the changes described in the LAR to validate the results of the analysis of the proposed post-shutdown Emergency Response Organization (ERO) presented in the LAR. This drill was conducted on February 22, 2017 and was observed by NRC staff.
Ll C-17 -0036 Attachment Page3 The training drill provided the opportunity for FCS to confirm the ability of the proposed post-shutdown ERO to perform the necessary functions of each Emergency Response Facility and to utilize the post-shutdown procedures developed reflecting the proposed revised assignment of duties. During this drill, FCS identified several opportunities to improve the deployment of Radiation Protection and emergency repair team resources from the Operations Support Center (OSC) and to improve the efficiency and performance of the on-shift and augmenting Radiation Protection (RP) Technicians by utilizing existing equipment and capabilities. Self-Reading Dosimeters and Dosimeters of Legal Record (DLRs) are typically located in each of the emergency lockers in the Control Room, Emergency Operations Facility (EOF), OSC and the Technical Support Center (TSC). Additional dosimeters and DLRs may be obtained by ERO personnel from the Radiation Protection department. The addition of a dosimetry kiosk and issuing terminal located in the OSC will allow for efficient and rapid issuance of dosimetry to repair teams. Additionally, closed-circuit television, and remote reading radiation telemetry that is installed in the areas required to perform mitigation activities to the Spent Fuel Pool (SFP) and areas containing SFP-related equipment augment the monitoring capability provided by installed radiation monitors. The output of these monitoring systems will be available in the TSC and OSC to the TSC Protective Measures Coordinator and OSC Director. This allows for real time monitoring of the radiological conditions in these areas for the Protective Measures Coordinator. Use of this technology can significantly reduce the exposure and time necessary to implement corrective measures.
FCS also identified opportunities for operating crews and command and control positions to align themselves to the emergency response priorities that exist in a permanently shut down and defueled facility. Operations and Radiation Protection departments at FCS have developed separate performance improvement plans to address the areas for improvement identified in the validation drill.
These plans and the associated actions have been entered into the station corrective action program and the actions will be completed prior to implementation of the PSEP.