ML18256A277

License Amendment Request for Change in Emergency Plan Staff Augmentation Response Times. Vistra Operations Company LLC, September 17, 2018

ML18256A277
Person / Time
Site:	Comanche Peak
Issue date:	09/17/2018
From:	Peters K Luminant, TXU Energy, Vistra Energy
To:	Watford M Plant Licensing Branch IV
Watford M, 301-415-1233
References
Download: ML18256A277 (9)

Text

License Amendment Request for Change in Emergency Plan Staff Augmentation Response Times Pre-Submittal Meeting for:

Vistra Operations Company LLC, Comanche Peak Nuclear Power Plant (CPNPP)

September 17, 2018

Participants

• USNRC

• CPNPP

AGENDA

• Pre-Submittal Meeting Purpose

• Emergency Plan Licensing Basis

• Proposed Emergency Plan Changes

• LAR Format

• LAR Schedule

• Conclusions

• Questions?

Pre-Submittal Meeting Purpose

• Establish communication with NRC staff in order to identify:

• applicable review criteria

• level of detail needed

• applicability of precedents

• feasibility of desired schedule

• Outline proposed Emergency Plan changes

• Discuss LAR Development process and preliminary content

CPNPP Emergency Plan Licensing Basis

• Last NRC Approved Plan - Revision 11, approved August 1989

• Current Emergency Plan - Revision 42, dated August 2018

• The LAR includes an analysis of the NUREG-0654 Table B-1 functions as implemented in the Emergency Plan between the last approved, current, and proposed revisions (example below).

Major Functional Area Major tasks Position Title/Expertise Table B-1 On-Shift CPNPP Rev 11 On-Shift CPNPP Rev 42 On-Shift CPNPP Proposed On-Shift Plant Operations & Assessment of Operational Aspects Shift Manager (SRO)

Unit Supervisor (SRO)

Reactor Operator (RO)

Nuclear Station Operator 1

1 2

2 1

1 3

3 1

2 4

7 1

2 4

7 Emergency Direction and Control Shift Manager (SRO) 1**

1**

1**

1**

Proposed Emergency Plan Changes

• Extend augmenting Emergency Response Organization (ERO) to 60 and 90 minute response times (from 40 and 70 respectively).

• Reduce the number of required ERO augmentation positions through consolidation and elimination.

Reason for Proposed Changes

• Significant increases in the number of on-shift positions have occurred over the years.

• Current, Revision 42 from August 2018 - 24 positions

• Last NRC-approved Emergency Plan, Revision 11 from 1989 - 10 positions

• ERO augmentation times at 40 and 70 minutes.

• Limits pool of qualified personnel to fill open ERO spots

• No credit provided for advances in technology, training and procedures that assist on-shift staff in coping with an event

LAR Format

• LAR follows NEI 06-02, License Amendment Request (LAR)

Guidelines

• Enclosures/Attachments include:

• Technical Justification based on improvements in plant systems, procedures, dose assessment, and training

• Contains a functional analysis of NUREG-0654, Table B-1 Major Tasks

• Summary table of Emergency Plan changes

• Marked up (red line) copy of the Emergency Plan

• Clean copy of the Emergency Plan

• ERO Task Analysis

• Table B-1 Comparative Chart

• Letters of Offsite Response Organization Concurrence

Regulatory Guidance

• RG 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors

• NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants

• NSIR/DPR-ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants

• RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation

• NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities

Precedents

• Susquehanna (ML030830543)

• Fermi (ML102700478)

• River Bend (ML012710218)

• Watts Bar (ML041810056)

• Point Beach (ML16118A54)

• Duane Arnold (ML16263A071)

• Monticello (ML17083A083)

• Prairie Island (ML17055C359)

• Wolf Creek (ML18135A145) [pending NRC review and approval]

LAR Schedule

• Submittal of LAR by 10/30/2018

• Request approval by 10/30/2019

• Propose a 180 day implementation period

Conclusions

• Proposed staffing continues to minimize impact of radiological emergencies and provides protection of public health and safety.

• Supported by Technical Justification and Functional Analysis.

• Revised Emergency Plan continues to meet §50.54(q)(2),

§50 Appendix E, and the planning standards of §50.47(b).

• Draft on-shift staffing analysis completed to verify that ERO positions were not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the Emergency Plan.

Questions?