ML19114A283
| ML19114A283 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/24/2019 |
| From: | James Anderson Office of Nuclear Security and Incident Response |
| To: | Quinn V Federal Emergency Management Agency, Area 8 |
| Joseph Anderson | |
| References | |
| Download: ML19114A283 (4) | |
Text
April 24, 2019 Vanessa Quinn, Chief Radiological Emergency Preparedness Branch Technological Hazards Division Federal Emergency Management Agency - Area 8 400 C Street, South West Washington, DC 20024
SUBJECT:
FEDERAL EMERGENCY MANAGEMENT AGENCY REVIEW REQUESTED OF REVISION TO THE INDIAN POINT ENERGY CENTER SITE EMERGENCY PLAN TO ADDRESS THE PERMANENTLY SHUT DOWN AND DEFUELED CONDITION
Dear Ms. Quinn:
By letter dated February 8, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17044A004), Entergy Nuclear Operations, Inc.
(Entergy) certified to the U.S. Nuclear Regulatory Commission (NRC), in accordance with Section 50.82(a)(1)(i) of Title 10 to the Code of Federal Regulations (10 CFR), that it plans to permanently cease power operations at Indian Point Nuclear Generating Units 2 (IP2) and 3 (IP3) by April 30, 2020 and April 30, 2021, respectively. Accordingly, by letter dated April 15, 2019 (ADAMS Accession No. ML19105B278), Entergy submitted for prior NRC approval, a license amendment request (LAR) to revise the Indian Point Energy Center (IPEC) Site Emergency Plan (SEP) to address the permanent cessation of power operations and defueled condition. Refer to URL below to access the LAR submittal.
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19105B278 Specifically, the proposed changes to the IPEC SEP would revise the licensees on-shift and augmented emergency response organization (ERO) staffing in response to the reduced spectrum of credible accidents, given the permanent cessation of power operations and permanent removal of fuel from the IP2 and IP3 reactor vessels. These proposed changes are not associated with any subsequent requests for exemption to NRC regulations and must continue to meet the standards of 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 Facilities."
Due to the planned one-year staggered shutdown dates for IP2 and IP3, Entergy has indicated that the proposed changes to the IPEC SEP address an interim Stage I period, during which IP2 will be permanently shut down and defueled, but IP3 will remain in operation.
The proposed Stage I changes would only affect the IP1 (currently in decommissioning) and IP2 on-shift staffs, with no changes to the augmented ERO staffing.
V. Quinn Entergy is also proposing Stage II changes to the IPEC SEP, which would address the period following IP3 permanent shut down and defuel, where no reactors are authorized to operate at the IPEC site. The Stage II changes will affect the IP2 and IP3 on-shift staffs, as well as the augmented ERO staffing.
Pursuant to 10 CFR 50.82(a)(i) and (ii), implementation of the proposed IPEC PSEP for either IP2 or IP3 would not occur until after Entergy certifies in writing to the NRC that the reactor has permanently ceased operations and fuel has been permanently removed from the reactor vessel. Upon docketing of these certifications, the 10 CFR Part 50 license for IP2, and subsequently IP3, will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessels.
Section 3.6, Assessment of Proposed Staffing Changes on Off-Site Response Organization Interfaces, of Enclosure 1 (Page 54 of 60), "Description and Evaluation of the Proposed Changes," to Entergy's April 15, 2019, submittal provides the licensee's assessment of the proposed staffing changes on offsite response organization interfaces.
Based on the results of this assessment, Entergy concluded the following:
The proposed changes do not reduce the ability of IPEC to provide the necessary information regarding the status and progression of an event or in the frequency at which event information updates are provided. Nor do the changes impact the ability to dispatch additional technical support to the EOCs. As a result, the proposed changes do not impact the ability of IPEC to communicate with the offsite response organizations or the ability of the State and County response organizations to effectively implement their FEMA-approved REP Plans.
In accordance with 10 CFR 50.91, "Notice of public comment: State consultation," paragraph b, Entergy has indicated that a copy of this application, with attachments, was provided to the designated New York State official.
The NRC's preliminary review of the proposed changes to the IPEC PSEP for Stages I and II indicates that these changes would not impact the methods or timing for the notification of State and local agencies of an emergency declaration and/or offsite protective action recommendation, offsite radiological monitoring and assessment capabilities, or the current location or timing of activation for the licensee's emergency response facilities. However, due to the extent of proposed changes to the licensee's ERO staffing, the NRC is requesting FEMA's review of the proposed licensee ERO staffing changes to verify that no potential adverse impacts exist that would preclude the effective implementation of the existing FEMA-approved State and local radiological emergency response plans and procedures.
Also, in Attachment 9, "List of Regulatory Commitments," to its April 15, 2019, submittal, Entergy states that prior to implementation of Stage II of the IPEC SEP (also, referred to as the Post Shutdown Emergency Plan):
A drill will be conducted to confirm the ability of the Stage II augmented emergency response organization to perform the necessary functions of each emergency response facility and to utilize the post-shutdown procedures being developed, depicting the revised assignment of duties. State and local response organizations will be offered the opportunity to participate, and the
V. Quinn NRC and FEMA will be provided advance notice and the opportunity to observe drill activities.
Entergy is requesting NRC approval of the proposed IPEC SEP by April 16, 2020.
However, based on the significant number of on-going and projected licensing actions, I am requesting that FEMA provide its assessment to the NRC by no later than July 12, 2019, to support any further request for additional information to Entergy, as needed to support the NRC's continued technical review and final determination, and completion and issuance of the safety evaluation report approving the licensing action.
As always, thank you for your assistance. If you have any questions regarding the changes proposed for Stages I and II of the IPEC SEP, the NRC's evaluation of these proposed changes, or if FEMA will be unable to meet the requested due date of July 12, 2019, please contact Richard Kinard at (301) 287-3768.
Sincerely,
/RA/
Joseph D. Anderson, Chief Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response cc: C. Fiore, FEMA HQ S. O'Neill, FEMA Region II
ML19114A283 OFFICE NSIR/DPR/RLB NSIR/DPR/RLB:BC NAME R. Kinard J. D. Anderson DATE 04/24/2019 04/24/2019