ML19163A023

Issuance of Amendment No. 186 Concerning Changes to Emergency Response Organization

ML19163A023
Person / Time
Site:	Perry
Issue date:	08/14/2019
From:	Kimberly Green Plant Licensing Branch III
To:	Payne F FirstEnergy Nuclear Operating Co
Green K
References
EPID L-2018-LLA-0484
Download: ML19163A023 (12)

Text

August 14, 2019 Mr. Frank R. Payne Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P.O. Box 97, SB306 Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 186 CONCERNING CHANGES TO EMERGENCY RESPONSE ORGANIZATION (EPID L-2018-LLA-0484)

Dear Mr. Payne:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 186 to Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, Unit No. 1 (PNPP). The amendment consists of changes to PNPP Emergency Plan in response to your application dated November 28, 2018.

The amendment revises the PNPP Emergency Plan to (1) transfer rescue and first aid duties from two on-shift security force members to on-shift fire brigade personnel and eliminate the two security force positions; (2) reduce the number of offsite radiation monitoring teams from three to two and transfer augmentation staff responsibility for onsite (out-of-plant) surveys from radiation monitoring teams to radiation protection technicians; (3) add definitions for offsite surveys and onsite (out-of-plant) surveys; and (4) make other administrative changes needed to implement the noted changes.

F. Payne A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Kimberly J. Green, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosures:

1. Amendment No. 186 to NPF-58

2. Safety Evaluation cc: Listserv

FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION, LLC DOCKET NO. 50-440 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 186 License No. NPF-58

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by FirstEnergy Nuclear Operating Company, et al. (the licensee, FENOC), dated November 28, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, by Amendment No. 186, Facility Operating License No. NPF-58 is hereby amended to authorize revision to the Perry Nuclear Power Plant Emergency Plan as set forth in the licensees application dated November 28, 2018, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3. This license amendment is effective as of its date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA Eric J. Benner for/

Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: August 14, 2019

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 186 TO FACILITY OPERATING LICENSE NO. NPF-58 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION, LLC PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By application dated November 28, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18332A500), FirstEnergy Nuclear Operating Company (the licensee or FENOC) requested changes to the Perry Nuclear Power Plant (PNPP) Emergency Plan pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes would revise the PNPP Emergency Plan to (1) transfer rescue and first aid duties from two on-shift security force members to on-shift fire brigade personnel and eliminate the two security force positions; (2) reduce the number of offsite radiation monitoring teams (RMTs) from three to two and transfer augmentation staff responsibility for onsite (out-of-plant) surveys from RMTs to radiation protection (RP) technicians; (3) add definitions for offsite surveys and onsite (out-of-plant) surveys; and (4) make other administrative changes needed to implement the noted changes.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance on which the U.S. Nuclear Regulatory Commission (NRC or Commission) staff based its review are provided below.

2.1 Regulatory Requirements The planning standards in 10 CFR 50.47(b) establish the requirements that the onsite and offsite emergency response plans must meet for the NRC staff to make a finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Specifically, on-shift and augmented emergency response organization (ERO) staffing is addressed under 10 CFR 50.47(b)(2), which states:

[10 CFR 50.47(b)(2)] On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely Enclosure 2

augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

The requirement for emergency medical support is in 10 CFR 50.47(b)(12), which states:

Arrangements are made for medical services for contaminated injured individuals.

In addition, Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV, Part A, Organization, states, in part, that The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization. . .

2.2 Guidance Regulatory Guide (RG) 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors, October 1981 (ADAMS Accession No. ML090440294), provides guidance on methods acceptable to the NRC staff for implementing specific parts of the NRCs regulations -

in this case, 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. RG 1.101 endorses Revision 1 to NUREG-0654/FEMA-REP-1 (NUREG-0654), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980 (ADAMS Accession No. ML040420012), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47(b). These criteria provide a basis for NRC licensees, and State and local governments to develop acceptable radiological emergency plans and to improve emergency preparedness.

NUREG-0654,Section II, Evaluation Criteria II.B.1 and II.B.5 address the planning standard in 10 CFR 50.47(b)(2).

Evaluation Criterion II.B.1 states:

Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal shift complement.

Evaluation Criterion II.B.5 states, in part:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1. . . .

NUREG-0654,Section II, Evaluation Criterion II.L.2 addresses the planning standard in 10 CFR 50.47(b)(12) and states:

Each licensee shall provide for onsite first aid capability.

Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (ADAMS Accession No. ML16124A002), provides examples of the scope and detail of information that should be provided in license amendment requests related to ERO staffing and augmentation to facilitate NRC review.

By letter dated June 12, 2018 (ADAMS Accession No. ML18022A352), the NRC staff provided alternative guidance to Evaluation Criterion II.B.5 in NUREG-0654, Revision 1, for minimum ERO on-shift and augmentation staffing. The letter states, in part:

The NRC has revised Section II.B, Table B-1 of NUREG-0654, based in part on comments received from the public on the draft Revision 2 of NUREG-0654, located at www.regulations.gov under Docket ID FEMA-2012-0026. The revised ERO staffing guidance has been finalized, and the NRC will include it when the entire NUREG-0654, Revision 2, is ready for issuance. Until then, the NRC staff is making available on an interim basis the ERO on-shift and augmentation staffing plan (attached). Regardless of whether a licensee chooses to use the guidance contained in Revision 1 of NUREG-0654, the attached, or an alternative approach, licensees are still required to adhere to 10 CFR 50.54(q) when revising their ERO staffing plans.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of the proposed changes to the PNPP Emergency Plan, as described in the application dated November 28, 2018.

3.1 Proposed Changes In its application dated November 28, 2018, FENOC provided a justification for the following proposed PNPP Emergency Plan changes:

Reduce the number of offsite RMTs by one from three to two, and transfer the responsibilities of onsite (out-of-plant) surveys to RP technicians; and Transfer the responsibilities for on-shift rescue and first aid from on-shift security personnel to the fire brigade.

Additionally, the application identified other changes, which are administrative in nature to support the implementation of the above changes. These changes include revising the definitions for offsite survey and onsite (out-of-plant) surveys.

The NRC staffs technical evaluation of the proposed changes to the PNPP Emergency Plan is described below.

3.1.1 Reduce the Number of Radiation Monitoring Teams In the current PNPP Emergency Plan, offsite and onsite (out-of-plant) surveys consist of two RMTs mobilized at the declaration of an Alert or higher classification level with a response time of 30 minutes. This initial RMT response was augmented by the mobilization of a third RMT at the declaration of a Site Area Emergency or higher classification level with a response time of 60 minutes. RMTs were normally comprised of one leader and one helper. The RMT Leader actions include reading dose rate instrumentation and obtaining air samples, if required. The RMT Helper actions include driving to and from field positions and communicating results to dose assessment personnel in the PNPP Technical Support Center and Emergency Operations Facility to support event classification and protective action recommendation development. The first two RMTs were responsible for monitoring for possible releases, and the third RMT was responsible for obtaining air samples and performing field measurements.

In the proposed PNPP Emergency Plan, mobilization of two offsite RMTs would continue to occur at the declaration of an Alert or higher classification level with a 30-minute response time, but the mobilization of a third RMT at the declaration of a Site Area Emergency or higher emergency classification is being eliminated. In lieu of a third RMT, FENOC proposes to mobilize one RP technician within 30 minutes of the declaration of an Alert or higher classification level and a second RP technician within 60 minutes to perform onsite (out-of-plant) surveys. In support of this change, FENOC proposed to also revise Table 5-1b, Perry Plant Emergency Response Organization Shift Staff Augmentation Functions and Staffing, to separate offsite and onsite (out-of-plant) survey activities.

FENOC stated that the RMTs will continue to be dispatched from a location just outside the Protected Area fence and use dose assessment instrumentation to perform environmental radiation assessments and plume tracking. The RMTs will also continue to be trained to conduct radiation surveys for plume tracking, perform air sampling, and provide radiological input for dose projections. As such, the proposed reduction in the number of RMTs does not adversely impact the ability to perform timely offsite surveys in the event of a potential or actual radiological release from the PNPP.

FENOC proposed to combine the onsite (out-of-plant) surveys major task with the in-plant surveys major task. FENOC further stated that shift and augmenting RP technicians performing these combined major tasks will meet or exceed the qualifications of the American National Standards Institute Standard N18.1-1971, Selection and Training of Nuclear Power Plant Personnel. To facilitate the use of an RP technician to perform onsite (out-of-plant) surveys, FENOC is proposing to redefine the boundary between the offsite and onsite (out-of-plant) survey areas as the Protected Area fence, rather than the site owner-controlled area fence, to reduce the survey area and remove the need for a vehicle and RMT Helper position. Based on the redefinition of the onsite (out-of-plant) survey area and in-plant and site radiological capabilities described by FENOC, the use of augmenting RP technicians does not adversely impact the ability to perform timely in-plant and onsite (out-of-plant) surveys in the event of a potential or actual radiological event at the PNPP.

Based on the assessment above, the NRC staff concludes that the proposed PNPP Emergency Plan continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.

3.1.2 Transfer the Responsibilities for On-Shift Rescue and First Aid from On-Shift Security Personnel to the Fire Brigade The guidance in NUREG-0654, Table B-1, specifies the Rescue Operations and First-Aid Major Functional Area should be fulfilled by two personnel on-shift that may be assigned other functions. To address rescue operations and first aid, the current PNPP Emergency Plan identifies two on-shift security force members who receive first aid training and are not included in the PNPP Security Plan response requirements.

FENOC proposed that the rescue operations and first aid function be performed by on-shift fire brigade personnel, as described in Section 3.2.3, Rescue Operations and First Aid Function, of the application, in lieu of two dedicated on-shift security force members. These two dedicated on-shift security force positions would be eliminated in the revised Table 5-1b.

FENOC stated that the fire brigade as a collateral duty is acceptable because the fire brigade is trained under the current PNPP Emergency Plan to perform rescue operations, which includes first aid. FENOC stated that an on-shift RP technician would continue to provide the necessary health physics coverage for rescue and first aid response activities.

FENOC performed a functional and staffing analysis to ensure that the proposed change does not result in a reduction of event response capability. The analysis demonstrated that the collateral use on-shift personnel to perform on-shift rescue and first aid, in conjunction with their currently assigned fire brigade emergency plan implementation functions, would not prevent the timely performance of these functions as specified in the PNPP Emergency Plan.

The NRC staff evaluated the proposed changes and determined that transfer of the rescue and first aid functions from the two on-shift security force members to the on-shift fire brigade personnel is acceptable because the fire brigade is already trained to perform these duties.

Further, the elimination of the two on-shift security force positions, which existed for purpose of performing the rescue operations and first aid, is acceptable because the duties will now be performed by the on-shift fire brigade, making the need for these two positions unnecessary.

Therefore, the NRC staff concludes that the proposed PNPP Emergency Plan continues to meet the standards of 10 CFR 50.47(b)(12) and the requirements of Appendix E to 10 CFR Part 50.

3.1.3 Other Administrative Changes The NRC staff reviewed the other miscellaneous changes to the PNPP Emergency Plan made to support the implementation of the changes above and determined that they are administrative in nature. Specifically, FENOC proposed to revise the definitions for offsite survey and onsite (out-of-plant) surveys to support the mobilization of RP technicians in lieu of a third RMT.

These definition changes, as well as the other administrative changes, were evaluated as part of the proposed changes in Sections 3.1.1 and 3.1.2 of this safety evaluation, and the NRC staff concludes that these changes do not negatively impact the licensees ability to continue to meet the standards of 10 CFR 50.47(b)(12) and the requirements of Appendix E to 10 CFR Part 50.

3.2 Summary The NRC staff performed a technical and regulatory review of the proposed changes to the PNPP Emergency Plan against the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, informed by the guidance provided in NUREG-0654, Regulatory Issue Summary 2016-10, and the NRC staffs letter dated June 12, 2018. This review included letters of concurrence from the State of Ohio and the local counties

of Lake, Geauga and Ashtabula, indicating that they had been briefed and concur on the proposed changes as not having a negative impact on offsite radiological emergency response plans. Based on this review, the NRC staff finds that the proposed PNPP Emergency Plan, as changed, continues to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Therefore, the NRC staff concludes that the proposed PNPP Emergency Plan changes to certain ERO staffing provisions, as described in the application dated November 28, 2018, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Ohio State official was notified of the proposed issuance of the amendment on June 11, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.21, 51.32, and 51.35, an environmental assessment and finding of no significant impact was published in the Federal Register on July 16, 2019 (84 FR 33993).

Accordingly, based upon the environmental assessment, the Commission has determined that the issuance of the amendment will not have a significant effect on the quality of the human environment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: J. Arce, NSIR M. Norris, NSIR Date of issuance: August 14, 2019

ML19163A023 *by email NSIR/DPR/RLB/BC* OGC (NLO OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA w/revisions)*

NAME KGreen SRohrer JAnderson STurk DATE 06/13/19 06/12/19 03/08/19 07/10/19 OFFICE NRR/DORL/LPL3/BC (A) NRR/DORL/DD NRR/OD NRR/DORL/LPL3/PM NAME LRegner GSuber HNieh (EBenner for) KGreen DATE 07/10/19 07/29/19 8/12/19 8/14/19