ML18285A818

NRR E-mail Capture - for Your Action: RAIs - Pilgrim - LAR - EP and EAL Scheme to Address Permanently Defueled Condition

ML18285A818
Person / Time
Site:	Pilgrim
Issue date:	10/12/2018
From:	John Lamb Special Projects and Process Branch
To:	Miner P Entergy Nuclear Operations
References
L-2018-LLA-0221
Download: ML18285A818 (4)

Text

NRR-DMPSPEm Resource From: Lamb, John Sent: Friday, October 12, 2018 2:26 PM To: Miner, Peter Cc: Byrne, Robert M; Couture III, Philip; Halter, Mandy

Subject:

FOR YOUR ACTION: RAIs - Pilgrim - LAR - EP and EAL Scheme to Address Permanently Defueled Condition (EPID: L-2018-LLA-0221)

Importance: High

Dear Mr. Miner:

By application dated August 1, 2018, (Agencywide Documents Access and Management System Accession No. ML18218184), Entergy Nuclear Operations, Inc. (Entergy), submitted changes to the site emergency plan (SEP) and emergency action level (EAL) scheme for the Pilgrim Nuclear Power Station for Commission review and prior approval pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes would revise the SEP and EAL scheme to reflect a permanently defueled condition.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensees submittal and determined that additional information is required to enable the NRC staff to make an independent assessment regarding its technical review.

The enclosure to this email provides the request for additional information (RAI). On October 10, 2018, the draft RAI questions were sent to you to ensure that they were understandable, the regulatory bases for the questions were clear, and to determine if the information was previously docketed. On October 12, 2018, you stated that a clarifying teleconference was not needed and that Entergy would respond to the RAI within 30 days of the date of this email.

If you have any questions, please contact me at 301-415-3100 or via e-mail at John.Lamb@nrc.gov.

Sincerely, John G. Lamb, Senior Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

Request for Additional Information ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION 1

RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGES TO THE PILGRIM NUCLEAR POWER STATION PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME ENTERGY NUCLEAR OPERATIONS, INC PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 By application dated August 1, 2018, (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML18218184), Entergy Nuclear Operations, Inc., submitted changes to the site emergency plan (SEP) and emergency action level (EAL) scheme for the Pilgrim Nuclear Power Station (PNPS) for Commission review and prior approval pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR).

The proposed changes would revise the SEP and EAL scheme to reflect a permanently defueled condition.

The NRC staff has reviewed the licensee's submittal and determined that additional information is required to enable the NRC staff to make an independent assessment regarding its technical review.

RAI-PNPS-1 Evaluation Criterion E.4 in Attachment 1 to NSIR/DPR-ISG-02 provides guidance on the contents of emergency messages based on the permanently shutdown and defueled condition of the facility, and includes that licensee will communicate a [m.] request for any needed onsite support by offsite organizations. However, the content of messages, as described in Section 5.1.2, Commonwealth and Local Government Notification, to Enclosure 1 of Entergys August 1, 2018 letter, does not appear to address this criterion.

Please describe the method being used by the licensee for conveying this information to State and local organizations, or basis for not addressing this criterion in emergency message content.

RAI-PNPS-2 Evaluation Criteria N.1.a and b in Attachment 1 to NSIR/DPR-ISG-02 state, in part:

a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations. Exercises shall be conducted as set forth in 10 CFR 50, as exempted, and in accordance with applicable portion to Section IV.G (Challenging Drills and Exercises) to NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants.

b. The scenario should be varied from year to year such that all major elements of the plans and preparedness organizations are tested.

Please explain why there is no provision in Section 14.0, Exercises and Drills, to Enclosure 1, page 25, of Entergys August 1, 2018 letter, for exercises and drills being conducted as set forth in 10 CFR 50, and in accordance with applicable portion to Section IV.G to NSIR/DPR-ISG-01, for the scenario to be varied from year to year.

RAI-PNPS-3 2

Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012 (ADAMS Accession Number ML12326A805) was endorsed by the NRC by letter dated March 28, 2013 (ADAMS Accession Number ML12346A463).

In Recognition Category PD EAL Bases, to Attachment 1, page 21, PD-AA1, EAL 3 states: Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the site boundary. However, it does not include the following NEI language - for one hour of exposure, nor is any justification provided for the difference.

Please explain why the reference NEI language is not included.

RAI-PNPS-4 In Recognition Category PD EAL Bases, to Attachment 1, page 28, PD-HU1, the following NEI language is absent: Escalation of the emergency classification level would be via IC PD-HA1, nor is any justification provided for the difference.

Please explain why the reference NEI language is not included.

3

Hearing Identifier: NRR_DMPS Email Number: 622 Mail Envelope Properties (John.Lamb@nrc.gov20181012142500)

Subject:

FOR YOUR ACTION: RAIs - Pilgrim - LAR - EP and EAL Scheme to Address Permanently Defueled Condition (EPID: L-2018-LLA-0221)

Sent Date: 10/12/2018 2:25:31 PM Received Date: 10/12/2018 2:25:00 PM From: Lamb, John Created By: John.Lamb@nrc.gov Recipients:

"Byrne, Robert M" <rbyrne@entergy.com>

Tracking Status: None "Couture III, Philip" <pcoutur@entergy.com>

Tracking Status: None "Halter, Mandy" <mhalter@entergy.com>

Tracking Status: None "Miner, Peter" <pminer@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 5425 10/12/2018 2:25:00 PM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: