ML17160A195
| ML17160A195 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Indian Point, Vermont Yankee  |
| Issue date: | 06/12/2017 |
| From: | Entergy Nuclear Operations |
| To: | Scott Wall Plant Licensing Branch III |
| Wall S | |
| References | |
| CAC MF9624, CAC MF9625, CAC MF9626, CAC MF9627, CAC MF9628 | |
| Download: ML17160A195 (21) | |
Text
Palisades Nuclear Plant June 12, 2017
Palisades Nuclear Plant (PNP)
Pre-Application Meeting License Amendment Requests (LAR)
Supporting a Permanently Defueled Condition 1
1
Introduction of Entergy Team
- Otto Gustafson - Director, Regulatory Assurance and Performance Improvement
- Dan Malone - Manager, Emergency Planning
- Amy Hazelhoff - Licensing Support
- David Daigle - Emergency Planning Support 2
Agenda
- Purpose
- Background
- Technical Specification (TS) ADMIN Section 5.0 LAR
- Scope
- Precedent Reviewed
- Examples
- Precedent Deviation
- Post Shutdown Emergency Plan LAR
- Overview
- Scope
- Staffing Levels
- Offsite Response Organizations
- Precedent Deviations
- Schedule 3
Purpose
- Provide overview of:
- ADMIN 5.0 LAR
- Facilitate NRC review
- Ensure LAR acceptance 4
=
Background===
- Certification to Permanently Cease Power Operations on October 1, 2018
- Submitted January 4, 2017 (ADAMS #ML17004A062)
- LARs support PNP Transition from an operating plant to a permanently defueled facility
- Supporting Submittals
- Certified Fuel Handler (CFH) Training and Retraining Program
- Submitted March 28, 2017 (ADAMS #ML17087A016)
- Severe Weather Exemption (10 CFR 73.55)
- Target submittal July 2018 5
ADMIN Section 5.0 LAR
- Scope
- TS Section 1.0 - Use and Application
- TS Section 5.0 - Administrative Controls
- Precedent Reviewed
- Entergy Nuclear Operations, Inc. (ENO)
- Vermont Yankee Amendment 260
- Exelon
- Oyster Creek Amendment 290 (3/7/17)
- NRC
- Power Reactor Transition from Operations to Decommissioning - Lessons Learned Report (10/16) 6
ADMIN Section 5.0 LAR Examples of Proposed Changes
- Position Title Changes
- Plant Superintendent to Plant Manager
- Shift Supervisor to Shift Manager
- Description Changes
- Safety of PNP to safe storage and handling of spent nuclear fuel
- Plant staff to facility staff
- Control Room command function to Shift command function
- Added Specifications
- Definitions for CERTIFIED FUEL HANDLER and NON-CERTIFIED OPERATOR
- Requirement that the Shift Manager shall be a CERTIFIED FUEL HANDLER
- Requirement for a NRC-approved Certified Fuel Handler training program
- Deleted Specifications
- Licensed Operators
- Shift Technical Advisor 7
ADMIN Section 5.0 LAR Precedent Deviation
- Precedence: NON-CERTIFIED OPERATOR
- A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER.
- PNP Proposed: NON-CERTIFIED OPERATOR
- A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 5.3.1.
- Basis: Eliminate potential conflict with proposed TS Section 5.2.2a.
- Each duty shift shall be composed of at least one shift manager and one NON-CERTIFIED OPERATOR. The NON- CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.
8
Post-Shutdown Emergency Plan LAR
- LAR Overview
- Attachment 1 - License Amendment Request
- Attachment 2 - Emergency Plan Change Summary
- Attachment 3 - PSEP Markup
- Attachment 4 - PSEP Clean
- Attachment 5 - Analysis of Proposed Post-Shutdown On-Shift Staffing
- Attachment 6 - Emergency Response Organization Task Analysis
- Attachment 7 - Commitments 9
Post-Shutdown Emergency Plan LAR
- Precedent Reviewed
- Entergy Nuclear Operations, Inc. (ENO)
- Vermont Yankee Amendment 261
- Omaha Public Power District
- NRC
- Power Reactor Transition from Operations to Decommissioning - Lessons Learned Report (10/16) 10
Post-Shutdown Emergency Plan LAR
- Analysis of Proposed Post-Shutdown On-Shift Staffing
- Post-Shutdown staffing was evaluated in conjunction with the postulated accidents that remain applicable in the permanently shutdown and defueled condition
- Post-Shutdown analysis considers the following scenarios:
- Design Basis Threat
- Fuel Handling Accident
- Aircraft Probable Threat
- Control Room Fire Requiring Evacuation
- General Emergency with Radioactive Release and Protective Action Recommendation (assumed for analysis purposes)
- Precedent Alignment
- Consistent with noted precedent 11
Post-Shutdown Emergency Plan LAR
- On-Shift Staff
- Permanently defueled condition:
- One (1) Shift Manager
- Two (2) Non-Certified Operators
- One (1) Radiation Protection Technician
- Five (5) person Fire Brigade maintained
- Precedent Alignment
- Consistent with noted precedent 12
Post-Shutdown Emergency Plan LAR
- ERO Augmentation by Facility:
- Technical Support Center (TSC)
- Emergency Plant Manager
- Engineering Coordinator
- Security Coordinator
- Emergency Notification System Communicator 13
Post-Shutdown Emergency Plan LAR
- ERO Augmentation by Facility:
- Operations Support Center (OSC)
- OSC Manager
- Radiation/Chemistry Coordinator
- Radiation Protection Technicians (3) 14
Post-Shutdown Emergency Plan LAR
- ERO Augmentation by Facility:
- Emergency Operations Facility (EOF)
- Emergency Director
- Technical Advisor
- Radiation Assessment Coordinator
- Offsite Communicator
- Offsite Team Coordinator
- Dose Assessor
- Offsite Field Monitoring Team
- Offsite Liaisons (4) 15
Post-Shutdown Emergency Plan LAR
- ERO Augmentation by Facility:
- Joint Information Center (JIC)
- Company Spokesperson
- Media Liaison
- Media Monitor
- Public Inquiry 16
Post-Shutdown Emergency Plan LAR
- ERO Position Differences
- Generally consistent with precedent
- Field Monitoring Team
- Proposed elimination of the 90-minute augmenting team
- No tasks identified for an additional augmenting team
- PNP would retain resources to supplement an additional Field Monitoring Team on an as-needed basis
- Chemistry Technician
- Proposed elimination of 60-minute augmenting Chemistry Technician
- No task identified in the post-shutdown condition that requires augmenting chemistry technician
- Proposed elimination of Lead Offsite Liaison
- Function of the Lead Offsite Liaison is being transferred to other EOF staff
- All necessary post-shutdown functions have been maintained and the ability of the ERO to perform these functions will be validated 17
Post-Shutdown Emergency Plan
- No Impacts to Offsite Response Organizations (ORO)
- OROs briefed on draft PSEP organization and interfaces
- PNP Offsite Liaison positions remain intact and will continue to be dispatched to the State and County Emergency Operations Centers (EOC) to act as communication liaisons between the EOCs and plant technical staff and to provide clarification of emergency response information
- Existing robust communication protocols remain in place
- State and County Radiological Emergency Plans (REPs) reviewed and no impacts were identified to existing support and interface 18
LAR Schedule
- Plan to submit in July 2017
- Validation Drill timing second quarter 2018
- Request NRC approval in July 2018
- Request an effective date:
- After PNP CFH Training and Retraining Program Approval AND
- After PNP Certifies Fuel Permanently removed from the reactor
- Request a 60 day implementation period 19