ML18310A380

Pre-Submittal Meeting Davis-Besse Nuclear Power Station (DB) Post-Shutdown Emergency Plan (PSEP) License Amendment Request

ML18310A380
Person / Time
Site:	Davis Besse
Issue date:	11/08/2018
From:	Blake Purnell Plant Licensing Branch III
To:	FirstEnergy Nuclear Operating Co
Purnell B
Shared Package
ML18310A388	List: ML18310A380
References
EPID L-2018-LRM-0067
Download: ML18310A380 (11)

Text

Davis-Besse Nuclear Power Station (DB) Post-Shutdown Emergency Plan (PSEP) License Amendment Request Pre-Submittal Meeting Davis-Besse Nuclear Power Station November 8, 2018

Post-Shutdown Emergency Plan License Amendment Request

Introductions

- Tom Lentz, Manager, FENOC Fleet Licensing

- Sean Zalesny, Manager, FENOC Fleet Emergency Planning

- Pat McCloskey, Manager, DB Regulatory Compliance

- Todd Kildoo, FENOC Fleet Emergency Planning

- Kathy Nesser, FENOC Fleet Licensing

- Jim Emley, FENOC Fleet Licensing

- David Daigle, ENERCON 2

Post-Shutdown Emergency Plan License Amendment Request Agenda

- License Amendment Request

- Need for Change

- Regulatory Bases

- Technical Justification

- Summary

- Open Discussion 3

Post-Shutdown Emergency License Amendment Request License Amendment Request

- Submittal Date

- Targeting December 2018

- Submittal Contents

- License Amendment Request

- Summary Table of Proposed Changes (with explanation)

- Emergency Plan - Markup

- Emergency Plan - Clean Version

- Augmented ERO Task Analysis Regulatory Relationship / Regulatory Margin 4

Post-Shutdown Emergency License Amendment Request Need for Change

- On April 25, 2018 FENOC announced the permanent shutdown of DB will be by May 31, 2020.

- Upon docketing of the certifications for permanent cessation of operations, DB will no longer be authorized to operate the reactor or place or retain fuel in the reactor vessel.

- As a result, there is a reduction in hazards associated with the permanently defueled condition.

- With respect to the emergency plan, this allows the facility staff to transition from an operating facility to a permanently defueled facility.

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Post-Shutdown Emergency Plan License Amendment Request Regulatory Bases

- 10 CFR 50.82(a)(i) and (ii) and10 CFR 50.82(a)(2)

- Notifications of permanent shutdown and fuel removal, which results in no longer being able to operate the facility.

- 10 CFR 50.47 and 10 CFR 50, Appendix E

- Provides the requirements for onsite emergency organization to respond to emergency events.

- These requirements are still applicable during this period.

- 10 CFR 50.54(q)

- Provides the guidance for evaluating Emergency Plan changes.

- If there is a reduction in effectiveness, then a License Amendment Request is required to request NRC approval.

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Post-Shutdown Emergency Plan License Amendment Request Regulatory Bases (continued)

- NUREG-0654

- Specifies the on-site emergency organization of plant staff personnel.

- These requirements are still applicable during this period.

- NSIR/DPR-ISG-01

- Provides information relevant to performing an on-shift staffing analysis. The ISG states that NEI 10-05 is an acceptable methodology for performing the staffing analysis.

- The staffing analysis provides the basis for staffing changes associated with the reduction in hazards associated with the permanently defueled condition.

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Post-Shutdown Emergency Plan License Amendment Request Technical Justification

- The reduction in hazards due to the permanently shutdown and defueled condition was identified. The hazards evaluated are:

- Waste Gas Decay Tank Rupture

- Design Basis Threat

- Fuel Handling Accident (FHA) with General Emergency and Protective Action Recommendation

- Probable Aircraft Threat [10 CFR 50.54(hh)]

- Fire Requiring Evacuation of the Control Room and Control of SFP Cooling

- The staffing analysis and the task analysis provides the basis for staffing changes associated with the reduction in hazards.

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Post-Shutdown Emergency Plan License Amendment Request Technical Justification (continued)

- Results of the analyses indicated that a reduction in both the on-shift and augmented ERO is appropriate.

- Supporting submittals

- Certified Fuel Handler (CFH) Training Program submitted on August 15, 2018.

- Technical Specifications (TS), Sections 1 and 5, License Amendment Request (LAR) submitted on October 22, 2018.

- Precedence

- Vermont Yankee

- Fort Calhoun

- Oyster Creek Regulatory Relationship / Regulatory Margin 9

Post-Shutdown Emergency Plan License Amendment Request Summary

- The PSEP LAR is based on a reduction in hazards associated with the permanently defueled condition.

- A on-shift staffing analysis and a functional analysis of the augmented ERO staff support the changes in the ERO staffing.

- The requirements of 10 CFR 50.47 and 10 CFR 50, Appendix E remain satisfied.

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