ML19267A018

Issuance of Amendment Nos. 172 and 172 to Revise Augmentation Times and Emergency Response Organization Staffing for the Emergency Plan

ML19267A018
Person / Time
Site:	Comanche Peak
Issue date:	11/04/2019
From:	Natreon Jordan Plant Licensing Branch IV
To:	Peters K Vistra Operations Company
Jordan N, 301-415-7410
References
EPID L-2018-LLA-0299
Download: ML19267A018 (25)

Text

November 4, 2019 Mr. Ken J. Peters Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Vistra Operations Company LLC Comanche Peak Nuclear Power Plant 6322 N FM 56 P.O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 172 AND 172 TO REVISE AUGMENTATION TIMES AND EMERGENCY RESPONSE ORGANIZATION STAFFING FOR THE EMERGENCY PLAN (EPID L-2018-LLA-0299)

Dear Mr. Peters:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 172 to Facility Operating License No. NPF-87 and Amendment No. 172 to Facility Operating License No. NPF-89 for Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (Comanche Peak), respectively. The amendments consist of changes to the Emergency Plan in response to your application dated October 31, 2018, as supplemented by letters dated March 28, 2019, and June 3, 2019.

The amendments revise staff augmentation times and reduce the number of required emergency response organization positions specified in the Comanche Peak Emergency Plan.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Natreon J. Jordan, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosures:

1. Amendment No. 172 to NPF-87

2. Amendment No. 172 to NPF-89

3. Safety Evaluation cc: Listserv

COMANCHE PEAK POWER COMPANY LLC AND VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-445 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 172 License No. NPF-87

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Vistra Operations Company LLC (Vistra OpCo) dated October 31, 2018, as supplemented by letters dated March 28, 2019, and June 3, 2019, 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.

2.

Accordingly, by Amendment No. 172, Facility Operating License No. NPF-87 is hereby amended to authorize revision to the Comanche Peak Nuclear Power Plant Emergency Plan as set forth in the licensees application dated October 31, 2018, as supplemented by letters dated March 28, 2019, and June 3, 2019, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

The license amendment is effective as of its date of issuance and shall be implemented within 180 days from 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: November 4, 2019

COMANCHE PEAK POWER COMPANY LLC AND VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NO. 2 DOCKET NO. 50-446 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 172 License No. NPF-89

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Vistra Operations Company LLC (Vistra OpCo) dated October 31, 2018, as supplemented by letters dated March 28, 2019, and June 3, 2019, 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 license 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.

2.

Accordingly, by Amendment No. 172, Facility Operating License No. NPF-89 is hereby amended to authorize revision to the Comanche Peak Nuclear Power Plant Emergency Plan as set forth in the licensees application dated October 31, 2018, as supplemented by letters dated March 28, 2019, and June 3, 2019, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days from 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: November 4, 2019

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 172 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 172 TO FACILITY OPERATING LICENSE NO. NPF-89 COMANCHE PEAK POWER COMPANY LLC AND VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-445 AND 50-446

1.0 INTRODUCTION

By application dated October 31, 2018 (Reference 1), as supplemented by letters dated March 28, 2019 (Reference 2), and June 3, 2019 (Reference 3), Vistra Operations Company LLC (Vistra OpCo, the licensee) submitted changes to the Comanche Peak Nuclear Power Plant (Comanche Peak or CPNPP), Unit Nos. 1 and 2 (Units 1 and 2), Emergency Plan (EP) for U.S. Nuclear Regulatory Commission (NRC, the Commission) review and prior approval pursuant to Section 50.54(q), Emergency plans, of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes would revise the Comanche Peak EP by changing the emergency response organization (ERO) staff augmentation times and reducing the number of ERO positions.

The supplemental letters dated March 28, 2019, and June 3, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register (FR) on January 2, 2019 (84 FR 26).

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance on which the NRC 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 the licensee can, and will, take adequate protective measures in the event of a radiological emergency. Specifically, on-shift and augmented ERO staffing is addressed under planning standard 10 CFR 50.47(b)(2), which states:

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

In addition, Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV, Content of Emergency Plans, 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 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors, dated October 1981 (Reference 4), provides guidance on methods acceptable to the NRC staff for implementing specific parts of the NRCs regulations, and more specifically in this case, 10 CFR 50.47(b)(2) and Appendix E to 10 CFR Part 50, Section IV, Part A.

Regulatory Guide 1.101 endorses Revision 1 of NUREG-0654/FEMA-REP-1 (hereafter referred to as NUREG-0654), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980 (Reference 5), 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 (EPs) and to improve emergency preparedness.

NUREG-0654,Section II, Planning Standards and Evaluation Criteria, 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.

In a letter to the Nuclear Energy Institute dated June 12, 2018 (Reference 6), the NRC staff provided alternative guidance for Evaluation Criterion II.B.5 in NUREG-0654, Revision 1, for minimum ERO on-shift and augmentation staffing. The letter stated, 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.

Hereafter, this guidance will be referred to as the revised NUREG-0654, Table B-1 in this safety evaluation.

Comanche Peak stated that it reviewed the revised NUREG-0654, Table B-1, during the preparation of the license amendment request (LAR) and determined that the proposed changes meet the intent of the revised NUREG-0654, Table B-1 (i.e., continues to adequately address the emergency functional areas of Table B-1).

Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (Reference 7), provides examples of the scope and detail of information that should be provided in LARs related to ERO staffing and augmentation to facilitate NRC review.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of the proposed changes to the Comanche Peak EP, as described in the application dated October 31, 2018, as supplemented by letters dated March 28, 2019, and June 3, 2019. The NRC staffs technical evaluation of the proposed Comanche Peak EP changes is detailed below.

3.1 Enhancements The NRC staff considered the overall enhancements in technology, information availability, and training, as described in Section 3.1, Technical Analysis, of Attachment 1, Evaluation of Proposed Change, of the LAR dated October 31, 2018, and summarized in the following paragraphs. These enhancements enable the on-shift staff to perform major functions and tasks more efficiently, which support the proposed changes in ERO staffing levels and response times.

Plant Process Computer The licensee states that the plant computer system (PCS) supports the safety parameter display system (SPDS) functions discussed below, as well as data collection and processing, accounting, alarming, and logging functions. The SPDS provides data to remote locations including the control room, technical support center (TSC), and emergency operations facility (EOF). The SPDS is a single operating platform incorporating the PCS and the SPDS, as well as the process computer system, meteorological data acquisition system, sequence of events recorder, and radiation monitoring.

The SPDS provides a concise display of critical plant variables to the control room personnel to assist them in rapidly and reliably determining the safety status of the plant. The SPDS is operated during normal plant operations, as well as during abnormal and emergency conditions.

The principal purpose and function of the SPDS is to assist the control room personnel during abnormal and emergency conditions in determining the safety status of the plant.

Parameters displayed by the SPDS are the quantitative and qualitative measures to indicate the accomplishment or maintenance of critical safety functions. Information needed to assess the status of the plant safety parameters is obtained by the measurement of key plant variables.

The safety parameters utilized by the SPDS to assess the maintenance or accomplishment of the critical safety functions include:

Reactivity control, Reactor core cooling and heat removal, Reactor coolant system integrity, Containment conditions, and Radiation control.

The licensee further states in the LAR that:

In addition to SPDS displays, the Technical Support Center and Emergency Operations Facility have access to the integrated Emergency Response Facility (ERF) Computer System. The ERF Computer System gathers, stores, and displays data needed in the TSC and EOF to analyze the plant conditions. The ERF Computer System performs its function independent of action in the Control Room and without degradation or interference with Control Room and plant functions.

Benefits of the current level of computer capabilities cited by the licensee include:

Improved plant monitoring capability for emergency functions.

Real time plant data available through graphic displays.

Multiple points of access.

Programming capability for automated response such as indication of critical parameter alarms.

Easier interface when switching between graphical displays.

Robust power supplies for PCS, SPDS and ERF Computer System.

Dose Assessment The licensee states, in part, in the LAR that:

A site-specific, computer-based dose assessment program is utilized at CPNPP.

The original software had accessibility limitations and lengthy processing times.

Computer displays of plant, radiological effluent, area radiation monitor, and meteorological information were available only from SPDS software on proprietary SPDS displays.

Over the years, modifications and upgrades have improved the availability, speed, and reliability of the dose assessment program. The dose assessor can

[now] obtain system parameters from the PCS, radiation monitor instrument readings from the Radiation Monitoring System (RMS), or results from in-plant sampling for input into the dose assessment software. These values are then used, along with meteorological parameters from the PCS, to calculate source terms and release rates necessary to estimate plume location and calculate projected doses to the public. Computers are provided in the appropriate emergency facilities to provide an alternate location of performing dose assessment if needed. The computing power of modern computer processors and data analysis allows calculation of projected downwind doses in seconds rather than minutes.

Automated ERO Call-Out Systems The licensee states, in part, in the LAR that:

Enhancements in automated call-out capability have resulted in streamlined processes for activation of the ERO. A web-based commercial service initiates notification of ERO members in lieu of individual calls to fill the [various ERO positions]. This system is regularly demonstrated during drills and exercises, and, periodically, in accordance with the CPNPP Emergency Plan and implementing procedures (EPIPs). Once activated, the process is automated requiring no additional actions from the on-shift staff.

Procedure Improvements The licensee states, in part, in the LAR that:

Emergency Operating Procedures (EOPs) have been improved through industry initiatives. EOPs are symptom-based, which demands less assessment and interpretation of plant conditions by the [on-shift] operating crews. In addition, the EOPs are flowcharted, better human-factored, and have an improved layout allowing for more consistent implementation. Parametric trend curves are generated by SPDS to graphically display plant conditions relative to EOP limits or required actions.

The licensee also states that emergency action levels (EALs) have been revised to incorporate the latest NRC-endorsed guidance, which has simplified the emergency classification process.

This includes the use of an overview matrix of EAL initiating conditions and threshold values,

which streamlines the process of evaluating EAL thresholds against plant conditions in the applicable EPIPs.

Training The licensee states, in part, in the LAR that:

Training is used to strategically drive improved performance. The application of the Systematic Approach to Training (SAT) has resulted in developing task lists for training programs. The SAT process ensures training is conducted to industry-accepted standards and has led to accreditation of the Operations and Technical Training programs.

The licensee further states that a dynamic simulator is routinely used during operations training.

As found simulator evaluations that include emergency response scenarios are part of the requalification program. Simulator scenarios are designed to be realistic and reflect a wide range of plant conditions, including emergency conditions. During evaluated simulator sessions, the control room staff is taken from normal operation to accident conditions, resulting in declaration of at least one emergency classification, which can range from a notification of Unusual Event to a General Emergency Classification Level (ECL). The crew performs critical tasks, classification, accident mitigation, response prioritization, and communications without augmentation from additional responders. The proficiency of the control room staff to perform these functions while maintaining situational awareness without additional support is assessed during evaluated simulator sessions.

Radiation Protection Improvements The licensee states that significant improvements have been made in radiation protection (RP) technology/tools associated with in-plant protective actions at Comanche Peak, which include:

Electronically controlled access to the radiologically controlled area (RCA), allowing RCA access without interfacing with a RP technician; Automated whole-body monitors for contamination monitoring without RP technician interface; and Use of self-alarming dosimeters.

The licensee further states that equipment and process improvements, combined with the establishment of emergency radiation work permits (RWPs) and emergency dose limits provide significant enhancements to efficient access control and reduce the need for direct RP technician support. These enhancements provide readily available information if an emergency is declared.

3.2 Major Functional Areas In the LAR dated October 31, 2018, the licensee provided a justification for the proposed Comanche Peak EP changes that included a detailed review of each major functional area as described in the NUREG-0654, Table B-1.

The current Comanche Peak EP describes the ERO as consisting of personnel staffing in the following ERFs:

Control Room Operations Support Center (OSC)

TSC EOF Joint Information Center (JIC)

Table 1.1, Staffing Requirements for Emergencies, to the Comanche Peak EP provides that the ERO currently augments the on-shift personnel within 40 minutes and 70 minutes of the declaration of an Alert or higher classification level in the OSC and TSC. Table 1.1 further indicates augmentation of personnel for the EOF at the declaration of a Site Area Emergency or General ECL. However, Table 1.1 currently does not specify a timeframe for this EOF augmentation.

The licensee proposes to augment specific positions in the OSC and TSC within 60 minutes and 90 minutes of the declaration of an Alert or higher classification level. The licensee will continue to notify the EOF and JIC personnel at the declaration of an Alert or higher classification level.

However, activation of the EOF and JIC is not required until a Site Area Emergency or higher classification level has been declared. The licensee proposes to revise Table 1.1 to reflect the expectation for the timely augmentation of the EOF and JIC within 60 minutes of the declaration of a Site Area Emergency or higher classification level. These proposed changes meet the guidance of revised NUREG-0654, Table B-1.

The NRC staffs review of the proposed changes to the Comanche Peak EP, as described below, is based on the major functional area provided in the Comanche Peak EP.

3.2.1 Major Functional Area: Station Operations and Assessment of Operational Aspects No changes are proposed for the on-shift staffing for the station operations and assessment of the operational aspects major functional area. The licensee states that there is only one augmenting position currently identified for this functional area, which is a plant nuclear equipment operator augmenting within 70 minutes to assist with beyond-design-basis external events and extended loss of all power events. Since the responder is not credited with actions to mitigate any postulated design-basis accident, Comanche Peak proposes to remove this augmented responder from the Comanche Peak EP and address the need for this responder in an appropriate beyond-design basis program document.

The licensee states that the on-shift staffing listed in the current Comanche Peak EP is in excess of the requirements in NUREG-0654, Table B-1, as well as that prescribed in the last NRC-approved Comanche Peak EP, Revision 11, dated August 1989. Additional personnel have been included in the existing on-shift complement for a total on-shift staffing of 24 persons.

This is an increase from 14 persons as specified in NUREG-0654, Table B-1, and the Comanche Peak EP, Revision 11. Revised NUREG-0654, Table B-1, does not include the station operations and assessment of operational aspects major functional area, but it acknowledges that the on-shift operations function is controlled by a site-specific technical specification or other licensing documents.

With the additional on-shift staff to help to ensure prompt response to a wide spectrum of emergency events without requiring immediate augmentation, the NRC staff finds that the proposed removal of one augmented nuclear equipment operator does not affect the ability or timing to perform required station operations and assessment of operational aspects from that outlined in the Comanche Peak EP.

Based on an evaluation of the above changes, the NRC staff has determined that the proposed Comanche Peak EP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A of Appendix E to 10 CFR Part 50 regarding station operations and assessment of operational aspects.

3.2.2 Major Functional Area: Emergency Direction and Control Revised NUREG-0654, Table B-1, recommends that following the declaration of an Alert or higher classification level, the TSC should be staffed with an emergency coordinator to relieve the control room. Additionally, the EOF emergency director position should be staffed within 60 minutes of the declaration of a Site Area Emergency or higher classification level in relief of the TSC.

The current Table 1.1 of the Comanche Peak EP has the TSC manager responding within 70 minutes of the declaration of an Alert or higher classification level to relieve the shift manager of the emergency coordinator duties. The licensee revised the Comanche Peak EP to indicate that the TSC manager will now respond within 60 minutes of the declaration of an Alert or higher classification level to relieve the shift manager of the emergency coordinator duties. The 60-minute augmentation time is consistent with revised NUREG-0654, Table B-1. This reduction in the time for augmentation of the TSC manager is considered by the NRC staff to be an enhancement, as it will allow the shift manager to promptly focus on event response from an operations perspective in a timely manner.

Based on an evaluation of the above changes, the NRC staff has determined that the proposed Comanche Peak EP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A of Appendix E to 10 CFR Part 50 regarding emergency direction and control.

3.2.3 Major Functional Area: Communications Revised NUREG-0654, Table B-1, recommends that following the declaration of an Alert or higher classification level, the TSC will be staffed with two communicators within 60 minutes and an additional communicator, as needed, within 90 minutes. In addition, revised NUREG-0654, Table B-1, recommends the staffing of one communicator in the EOF within 60 minutes of declaring a Site Area Emergency or General ECL.

The current Table 1.1 of the Comanche Peak EP has one dedicated on-shift communicator and one on-shift communicator who can be assigned other functions, such as an emergency notification system (ENS) communicator. The licensee proposes to combine the on-shift communicator functions into one dedicated position. The on-shift communicator may be any on-shift personnel with the requisite training and qualification, as defined in the EPIPs. The licensee states that dedicated telephone circuits and the use of a wireless headset enable a single communicator to perform State and county notifications on one line, while maintaining an open line with the NRC on the ENS. The licensee further states that this capability has been successfully demonstrated in simulator drills conducted at Comanche Peak. Notification of

licensee ERO personnel is initiated through an automated call-out process, which is not being changed.

The current Table 1.1 of the Comanche Peak EP also has two augmenting communicators reporting to the TSC within 70 minutes of the declaration of an Alert or higher classification level. The proposed change would reduce the two TSC communicators augmentation time for to within 60 minutes of the declaration of an Alert or higher classification level, which aligns with revised NUREG-0654, Table B-1. This reduction in the time for augmentation of the TSC communicators is considered by the NRC staff to be an enhancement, as it will relieve the on-shift communicator of the communication duties at an earlier time, enhancing communications with State and county points of contact and the NRC.

In addition, Table 1.1 of the Comanche Peak EP is being changed to reflect that the EOF communicator position will be augmented within 60 minutes of the declaration of a Site Area Emergency or General ECL.

Based on an evaluation of the above changes, the NRC staff has determined that the proposed Comanche Peak EP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A of Appendix E to 10 CFR Part 50 regarding communications.

3.2.4 Major Functional Area: Security Revised NUREG-0654, Table B-1, does not include the security major functional area. It acknowledges that the on-shift security function is controlled by a site-specific technical specification or other licensing documents.

No changes are proposed to Table 1.1 of the Comanche Peak EP pertaining to security. The Comanche Peak EP identifies that a security shift supervisor and security officers (per the Security Plan) will be on-shift, and a security coordinator will augment the EOF within 60 minutes of the declaration of a Site Area Emergency or General ECL.

3.2.5 Major Functional Area: Public Information Revised NUREG-0654, Table B-1, recommends that the JIC staff address media inquiries within 60 minutes of the declaration of an Alert or higher classification level, but notes that this function does not need to be performed at the TSC or OSC. Revised NUREG-0654, Table B-1, further recommends additional staff to perform JIC functions within 60 minutes of the declaration of a Site Area Emergency or General ECL.

The current Table 1.1 of the Comanche Peak EP has the TSC manager assuming responsibility for the approval of the release of public information from the shift manager within 70 minutes of the declaration of an Alert or higher classification level. Both positions are identified in Table 1.1, as the function can be provided by other on-shift or augmented personnel assigned other functions.

The proposed change would reduce the TSC managers augmentation time from 70 minutes to within 60 minutes of the declaration of an Alert or higher classification level to manage and coordinate media information related to an event. The 60-minute augmentation time is consistent with revised NUREG-0654, Table B-1. This reduction in the time for augmentation of the TSC manager is considered by the NRC staff to be an enhancement, as it will relieve the

shift manager of the public information duties, thus allowing the shift manager to focus on plant operational aspects at an earlier time.

No changes to the augmentation time for the company spokesman in the EOF are proposed.

The company spokesman will continue to augment within 60 minutes of the declaration of a Site Area Emergency or General ECL.

Based on an evaluation of the above changes, the NRC staff has determined that the proposed Comanche Peak EP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A of Appendix E to 10 CFR Part 50 regarding public information.

3.2.6 Major Functional Area: Logistics The current Table 1.1 of the Comanche Peak EP has the TSC communications coordinator assuming the responsibility for obtaining/expediting needed resources for the ERO from the shift manager within 70 minutes of the declaration of an Alert or higher classification level. Both positions are identified as collateral functions in the current Table 1.1. The responsibility would then transfer to the EOF logistical support coordinator upon declaration of a Site Area Emergency or higher classification level. However, revised NUREG-0654, Table B-1, does not include logistics as a major functional area.

The proposed change would transfer the responsibility for logistics from the TSC communication coordinator to the TSC manager and reduce the augmentation time from 70 minutes to 60 minutes from the declaration of an Alert or higher classification level. The licensee states that reassigning the task from the TSC communication coordinator will not impact this functional area, as the emergency coordinator can transfer this responsibility at any time per procedural guidance and Note (a) in Table 1.1 of the Comanche Peak EP. Additionally, the EOF logistical support coordinator was removed from Table 1.1, as required for minimum staffing in the EOF.

This reduction in the time for augmentation of the TSC manager is considered by the NRC staff to be an enhancement, as it will relieve the shift manager of the logistics duties and will allow the shift manager to focus on plant operational aspects at an earlier time. Since this duty is designated as a collateral duty and is not included as a functional area in revised NUREG-0654, Table B-1, the NRC staff finds the above describe changes acceptable.

Based on an evaluation of the above changes, the NRC staff has determined that the proposed Comanche Peak EP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A of Appendix E to 10 CFR Part 50.

3.2.7 Major Functional Area: Station System Engineering Revised NUREG-0654, Table B-1, recommends that the TSC minimum staff for the engineering function consist of one core/thermal hydraulics engineer to support the evaluation of reactor conditions, one mechanical engineer for the assessment and repair of mechanical equipment, and one electrical/instrumentation and control (I&C) engineer for the assessment and repair of electrical and I&C equipment.

The current Comanche Peak EP identifies the on-shift shift technical advisor (STA) for technical support. The STA functions in an oversight role for the evaluation of operating conditions and providing the core/thermal hydraulic technical support function on shift. The STA also performs

assigned technical support activities required by operating procedures, technical specifications, and EPIPs.

The current Table 1.1 of the Comanche Peak EP requires augmentation at 70 minutes upon declaration of an Alert or higher classification level by the TSC engineering team coordinator and a team of four engineers. The proposed change would augment two engineers with expertise in electrical/I&C and mechanical systems and equipment within 60 minutes from the declaration of an Alert or higher classification level. The proposed change will also have the engineering team coordinator, and an engineer responsible for monitoring and evaluating changing core/thermal hydraulic issues, to respond within 90 minutes from the declaration of an Alert or higher classification level.

The licensee stated that the proposed change would realign the engineering team to provide a minimum of three engineers possessing experience and competence in three separate areas:

1. monitor and evaluate changing core/thermal hydraulic issues to support timely corrective action(s), ECL declarations, and subsequent PARs

[protective action recommendations];

2. expertise in electrical/instrumentation and control (I&C) systems and equipment to support the development of repair plans if necessary; and

3. expertise in mechanical systems and equipment to support the development of repair plans if necessary.

The licensee stated that the proposed change reflects the primary functions of the engineering team as postulated in revised NUREG-0654, Table B-1, and provides a better-defined list of competencies than those provided in the current Comanche Peak EP.

The licensee further stated that for the proposed augmentation of an engineer to monitor and evaluate changing core/thermal hydraulic issues responding within 90 minutes from the declaration of an Alert or higher classification level, the STA is trained and qualified to perform the tasks normally assigned to the TSC nuclear engineer upon augmentation. The STA will not have any collateral duties to focus on other than its primary responsibility of providing engineering expertise and advice regarding plant transient analysis, accident mitigation, core/thermal hydraulics, and other matters related to operational safety to the operating staff, as identified in the Comanche Peak EP. Qualified STAs are familiar with each of these tasks, several of which directly parallel those assigned to the STA. These supporting tasks were reviewed to determine if the STA has the training, knowledge, and tools necessary to accomplish these tasks in a timely manner without distracting the STA from their primary duties/responsibilities. In each instance, the STAs training and qualification program does provide the necessary knowledge and skills, and for each of the above tasks, the STA is provided the same procedures and tools (forms, spreadsheets, reference materials) as the augmenting TSC nuclear engineer.

This reduction in the time for augmentation of the two augmented engineers with expertise in electrical/I&C and mechanical systems and equipment from within 70 minutes to 60 minutes from the declaration of an Alert or higher classification level is considered by the NRC staff to be an enhancement, as it will provide engineering expertise in an earlier timeframe and is consistent with revised NUREG-0654, Table B-1. Additionally, the extension in augmentation of an engineer to monitor and evaluate changing core/thermal hydraulic issues within 90 minutes

from the declaration of an Alert or higher classification level is acceptable, as the STA is trained and qualified to perform the tasks normally assigned to the TSC nuclear engineer upon arrival in the TSC.

Based on an evaluation of the above changes, the NRC staff has determined that the proposed Comanche Peak EP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A of Appendix E to 10 CFR Part 50 regarding station system engineering.

3.2.8 Major Functional Area: Radiological Accident Assessment and Support of Operational Accident Assessment The radiological assessment functional area includes chemistry/radiochemistry, in-plant and onsite surveys, offsite surveys, offsite dose assessment, protective actions, and coordination and control.

Chemistry/Radiochemistry The current Comanche Peak EP requires one chemistry technician to be on shift. The licensee states that the on-shift chemistry technician performs chemistry/radiochemistry tasks until relieved by the augmenting chemistry technician. Currently, the Comanche Peak EP augmentation time for the chemistry technician is 70 minutes upon declaration of an Alert or higher classification level. The proposed change would extend the augmentation time to 90 minutes from the declaration of an Alert or higher classification level. No chemistry samples are required by technical specifications within the 90-minute period after a declaration; therefore, the 20-minute extension in augmentation time does not impact performance of this function. Additionally, this duty is not included as a functional area in revised NUREG-0654, Table B-1.

Since the increase in the time for augmentation of the chemistry technician does not impact the performance of the chemistry/radiochemistry function within the first 90 minutes of the declaration of an Alert or higher emergency classification, the NRC staff finds the changes described above to be acceptable.

Protective Actions, In-Plant, and Onsite Surveys The current Comanche Peak EP requires two RP technicians to be on shift. The licensee states that the on-shift RP technicians are responsible for in-plant and onsite surveys, as well as onsite radiological protective actions until the augmenting RP technicians arrive. The on-shift RP technicians and the RP technician augmented responders are qualified to perform assigned tasks, which include access control duties, RP coverage for workers, personnel monitoring, and dosimetry.

The current Table 1.1 of the Comanche Peak EP provides that two RP technicians are assigned to respond within 40 minutes and five RP technicians are assigned to respond within 70 minutes from the declaration of an Alert or higher classification level to assume protective action tasks.

Revised NUREG-0654, Table B-1, identifies three RP technicians, in addition to RP technicians on shift and staffing the OSC within 60 minutes of the declaration of an Alert or higher classification level. Revised NUREG-0654, Table B-1, also lists an additional three RP

technicians staffing the OSC within 90 minutes of the declaration of an Alert or higher classification level.

The licensee proposed that the augmentation for this function occur in two stages, consisting of an additional three RP personnel staffing the OSC within 60 minutes and an additional three RP personnel staffing the OSC within 90 minutes from the declaration of an Alert or higher classification level, which is consistent with the guidance in revised NUREG-0654, Table B-1.

The RP technicians and the RP technician augmented responders are qualified to perform assigned tasks, which include access control duties, RP coverage for workers, personnel monitoring, and dosimetry. The licensee stated that originally, radiological access control was a labor-intensive task. This required RP technicians to check dose margins, training qualifications, and ensure workers had read and understood the RWP. However, in recent years, worker access control has become automated and radiation protection work has become computerized. As a result, RWPs, access control, and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on RWPs and to self-issue electronic dosimeters.

The licensee further states that the performance of RP coverage for response action activities will continue to be performed initially by the on-shift RP technician. RP coverage will only be performed if the radiological status of a room/area is unknown and there is a definitive need for emergency workers to enter the room/area to perform a task. The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed area radiation monitors (ARMs). During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, RP coverage would not be required for all areas. If RP coverage is deemed necessary, emergency teams can be covered by the on-shift and augmenting RP technicians. If RP coverage is not provided (for entry into area with low radiological risk or known radiological status), emergency workers are required to wear electronic dosimeters that alarm at preset dose and dose rate setpoints. In addition, installed ARMs, which alarm locally and remotely at preset dose rates, are located throughout the plant.

Revised NUREG-0654, Table B-1, recommends one onsite field monitoring team (FMT). The current Comanche Peak EP, Table 1.1, specifies that the on-shift RP technicians are responsible for in-plant and onsite surveys, as well as radiological protective actions until the augmenting RP technicians arrive. Section 7.3.1, Onsite Radiological Assessment, of the Comanche Peak EP states, in part, that Initially, during an emergency condition, the on-shift Radiation Protection and Chemistry Technicians perform onsite and in-plant radiological assessment, and sampling activities, respectively, as directed by the Shift Manager.

Once the TSC is activated, responsibilities for onsite and offsite radiological assessment and survey activities shall be assumed by the TSC Onsite Radiological Assessment Coordinator. As CPNPP Emergency Organization personnel become available, onsite radiological survey teams shall be formed as required and dispatched from the OSC.

The licensee states that onsite surveys or installed post-accident effluent radiation monitors provide rapid indications of a release of radioactive materials and can be used for offsite dose assessment calculation purposes. Prior to 60-minute augmentation, in-plant radiation monitoring instrumentation would be used to determine release information because radiological

release instrument data is easily obtained. The additional response time for initial survey team personnel is supported by the use of in-plant instrumentation, installed monitoring capability, and in-plant and onsite surveys by on-shift personnel as available to support site dose assessment and protective actions.

Based on the technological advances in protection coverage for responders, in-plant surveys, dosimetry, and RCA access, as described in Attachment 1 of the LAR, the NRC staff finds that the proposed changes to the staffing for the protective actions and in-plant and onsite surveys are acceptable.

Offsite Surveys Revised NUREG-0654, Table B-1, recommends two offsite FMTs as minimum staff. Each FMT would consist of a driver and one individual (i.e., a field monitor) qualified to assess the area for radiation and contamination. Each field monitor will also provide RP coverage for the team as directed by the TSC RP manager or EOF RP manager. The field monitors for the offsite FMTs would also provide for the tracking of the plume from any potential radiological release. The onsite FMT and one offsite FMT are recommended in revised NUREG-0654, Table B-1, to be staffed within 60 minutes, and the second offsite FMT is recommended to be staffed within 90 minutes from the declaration of an Alert or higher classification level.

The current Table 1.1 of the Comanche Peak EP lists two RP technicians responding in 40 minutes and two drivers in 70 minutes from the declaration of an Alert or higher classification level to perform offsite surveys. The licensee is proposing to retitle the two RP technician positions to offsite radiological monitor. The licensee explained that the title change allows the position to be filled by anyone who has the applicable radiation monitoring training required for field team qualification and is not limited to RP technicians. Job-specific training will be developed using the SAT process and provided for all personnel assigned to offsite radiological monitoring responsibilities. However, the tasks performed by this position have not changed. In addition, this change will expand the number of RP technicians available to perform other critical RP functions without adversely impacting the ability to effectively perform offsite surveys.

Additionally, the licensee is proposing to have the offsite radiological monitor position augment at 60 minutes from an Alert or higher classification level and two vehicle drivers augment at 90 minutes from an Alert or higher classification level. The licensee states that this staggered augmentation by the radiological monitoring team member and driver has been employed at Comanche Peak for many years and has not presented challenges to mobilizing teams to perform offsite field monitoring in a timely manner. Staggering the augmentation timing of these roles allows the RP technician (or offsite radiological monitor) to receive necessary briefings on plant and release conditions; obtain instruments, supplies, and vehicles for the team; and complete initial response and operational checks of the equipment prior to arrival of the drivers.

If dispatch of the offsite FMT is necessary prior to driver arrival, the offsite radiological monitor is appropriately trained and can function in the interim as the driver. Once the augmenting vehicle drivers arrive, the offsite radiological monitors would pair with the dedicated drivers and divide into two separate monitoring teams.

The licensee further states that offsite FMTs will function with limited RP expertise while under the direct supervision of senior RP staff in the TSC or EOF, thus removing the need for a fully qualified RP staff member being a part of FMTs when the staff members expertise is better suited supporting the ERO onsite. The senior RP staff supervising the offsite FMTs is responsible for directing the teams, as well as providing direction for the teams safety from the

radiological event. If the offsite FMTs are dispatched by the OSC, the TSC onsite radiological assessment coordinator (OnRAC) maintains direction and control of the offsite FMTs aided by the OSC RP coordinator position, which augments at 90 minutes from the declaration of an Alert or higher classification. If the offsite monitoring team is dispatched by the EOF, the offsite monitoring team director, who reports to the EOF RP coordinator, is responsible for direction and control of the offsite radiological monitoring team.

Based on the evaluation above, and as described in Attachment 1 of the LAR, the NRC staff finds that the proposed changes to the staffing for the offsite surveys are acceptable.

Offsite Dose Assessment:

Currently, Table 1.1 of the Comanche Peak EP provides that the STA performs dose assessments on shift as a collateral duty with the TSC OnRAC augmenting within 40 minutes from the declaration of an Alert or higher classification level and the EOF dose assessor augmenting within 60 minutes from the declaration of a Site Area Emergency or higher classification level.

The licensee is proposing to assign this function to the on-shift chemistry technician and extend the augmentation time for TSC OnRAC position from 40 to 60 minutes from the Alert or higher classification level. The dose assessment function will be further augmented by the EOF dose assessor within 60 minutes of the declaration of a Site Area Emergency or higher classification level. The licensee stated that the improvements made to the radiation monitoring system user interface (that walks the user through the data entry process), the addition of built-in help screens, and the use of software with default parameters (that can be overridden by the user) to facilitate the ability of the on-shift chemistry technician, accurately generate dose assessments using actual meteorology.

The licensee stated that although there are no automated inputs to the software, the need for manual inputs has been minimized, and the PCS data displays have been consolidated to prevent the dose assessor from needing to access multiple sources for input data. In addition, output displays (screen and print) from the software highlight any areas exceeding U.S. Environmental Protection Agency Protective Action Guidelines and automatically provide the recommended protective actions per station procedures.

Based on the evaluation above, and as described in Attachment 1 of the LAR, the NRC staff finds that the proposed changes to the staffing for the offsite dose assessment are acceptable.

In conclusion, the NRC staff finds that the proposed Comanche Peak EP continues to meet the planning standard of 10 CFR 50.47(b)(2) as well as the requirements in Section IV.A to Appendix E of 10 CFR Part 50 for radiological accident assessment and support of operational accident assessment.

3.2.9 System Corrective Action The guidance in NUREG-0654, Table B-1, upon which the current Comanche Peak EP is based, specifies that the major task of repair and corrective actions is to be fulfilled on shift by a total of two personnel and [m]ay be provided by shift personnel assigned other functions. One person would perform the function of a mechanic and one person would perform the function of an electrician. NUREG-0654, Table B-1, specifies that one electrician and one I&C technician would respond within 30 minutes after declaration of an emergency to augment the ERO. In

addition, one mechanic, one rad waste operator, and one additional electrician would respond within 60 minutes after declaration of an emergency to augment the ERO.

The revised NUREG-0654, Table B-1, indicates that an on-shift repair team is not needed to support the EP. Augmentation of the repair team personnel would be by one mechanic and one electrician within 60 minutes of an Alert or higher classification level. Additional augmentation would add one I&C technician within 90 minutes of an Alert or higher classification level.

Currently, the Comanche Peak on-shift complement includes a mechanic, an electrician, and an I&C technician to perform emergent repairs, with augmentation of additional maintenance personnel within 70 minutes from the declaration of an Alert or higher classification level.

The licensee stated that the Comanche Peak licensing basis includes the use of safety systems designed to protect against (1) accident sequences leading to core melt and consequent degradation of the containment boundary, and (2) accident sequences leading to fuel clad failure or partial melt with independent failures of the containment boundary. The Comanche Peak engineered safety feature (ESF) systems are designed to limit the potential radiation exposure to the public, as well as to plant personnel, in the unlikely occurrence of any of these accident sequences. The following ESFs are designed to localize, control, mitigate, and terminate all such postulated accidents:

Emergency Core Cooling System Safety Injection System Containment Spray System Residual Heat Removal System.

The licensee further stated that during the initial stages of an event, the scope of repair and corrective actions performed by on-shift personnel is typically limited to actions that promptly restore a non-functional component or system to functional status (e.g., resetting a relay or logic manipulation) or to place a component or system in a desired configuration such as opening a valve or closing a breaker. Nuclear equipment operators are trained and qualified to perform actions in response to plant events consistent with system responses as noted in EOPs and abnormal operating procedures. Therefore, the Comanche Peak on-shift nuclear equipment operators have the requisite training and expertise to perform this level of minor maintenance actions as directed by the unit supervisor and are available to satisfy any minor troubleshooting and repair activities that might be needed until augmenting staff arrives.

As such, the proposed change would remove the dedicated on-shift maintenance personnel and have these duties revert to being performed by personnel assigned other functions (e.g., nuclear equipment operators) prior to augmentation. Augmentation of the repair team personnel would consist of the OSC manager, one mechanic, and one electrician within 60 minutes from the declaration of an Alert or higher classification level. Additional augmentation would add the OSC RP coordinator, OSC emergency repair and damage control (ERDC) coordinator, and one I&C technician within 90 minutes from the declaration of an Alert or higher classification level. This proposed staffing is consistent with revised NUREG-0654, Table B-1, which will ensure that adequate maintenance and repair expertise is available in a timely manner.

The augmented maintenance responders provide additional resources for repair and corrective actions. In addition, the OSC RP coordinator and OSC ERDC coordinator provide dedicated radiological and maintenance planning capabilities in support of the repair teams. Supervision

of the maintenance and repair personnel is provided by the OSC manager, who ensures that the emergency coordinator has access to needed resources and expertise in order to develop coordinated response plans for a wide spectrum of events.

Based on evaluation of the above changes, the NRC staff has determined that with the proposed changes, the Comanche Peak EP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A of Appendix E to 10 CFR Part 50 regarding System Corrective Action.

3.2.10 Major Functional Area: Firefighting and Rescue The guidance in NUREG-0654, Table B-1, specifies that the firefighting major functional area is to be fulfilled on shift by the fire brigade per technical specifications and augmented by local support after declaration of an emergency. The guidance in revised NUREG-0654, Table B-1, does not include firefighting and rescue as a major functional area but acknowledges that the on-shift firefighting and rescue response is controlled under site-specific technical specifications or other licensing documents.

The licensee stated that the fire brigade will continue to be staffed in accordance with the sites fire protection program. Therefore, Comanche Peak is not proposing a change to the firefighting major functional area. As such, the NRC staff has determined that the proposed Comanche Peak EP continues to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A to Appendix E of 10 CFR Part 50 regarding firefighting and rescue.

3.2.11 Major Functional Area: Medical The guidance in NUREG-0654, Table B-1, specifies the rescue operations and first-aid major functional area to be fulfilled by two personnel on shift who may be assigned other functions and augmented by local support after declaration of an emergency. The guidance in revised NUREG-0654, Table B-1, does not include firefighting and rescue as a major functional area.

The current Comanche Peak EP provides two personnel to perform the Rescue Operations and First Aid Major Functional Area, which meets the requirement for qualified on-shift personnel to provide first-aid treatment for injured personnel. Local support organizations will continue to support rescue operations and first-aid per the agreements established with these organizations.

The current Comanche Peak EP also provides that a first-aid station is maintained on site equipped with standard supplies such as bandages, splints, and stretchers. In addition, first-aid kits with basic supplies are located throughout Comanche Peak. Eyewash stations are also located throughout the plant at strategic locations.

Since the licensee is not proposing a change to the medical major functional area at Comanche Peak, the NRC staff has determined that the proposed Comanche Peak EP continues to meet the planning standard 10 CFR 50.47(b)(2) and the requirements in Section IV.A to Appendix E of 10 CFR Part 50 regarding medical.

3.3 ERO Staffing Reductions In addition to the changes discussed above, the licensee is proposing to eliminate the EOF contract coordinator position and transfer responsibility for obtaining supplies and coordinating

vendor contracts, when requested, to the procurement coordinator position to alleviate redundancy in job tasks within the EOF. Neither of these ERO positions is identified in revised NUREG-0654, Table B-1.

Based on an evaluation of the above change, the NRC staff has determined that the proposed Comanche Peak EP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A of Appendix E to 10 CFR Part 50.

3.4 Summary The NRC staff performed a technical and regulatory review of the proposed changes to the Comanche Peak EP. Based on this review, the NRC staff finds that the proposed Comanche Peak EP, as changed, continues to meet the standard of 10 CFR 50.47(b)(2) and the requirements in Section IV.A to Appendix E of 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 Comanche Peak EP changes to certain ERO staffing and augmentation times, as described in the licensees application dated October 31, 2018, as supplemented by letters dated March 28, 2019, and June 3, 2019, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Texas State official was notified of the proposed issuance of the amendments on September 19, 2019. The State official expressed no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the site emergency plan. The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20, and also relate to changes in recordkeeping, reporting, or administrative procedures or requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register on January 2, 2019 (84 FR 26), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1.

McCool, T. P., Vistra Energy, letter to U.S. Nuclear Regulatory Commission, Comanche Peak Nuclear Power Plant, Docket Nos. 50-445, 50-446, and 72-74, License Amendment Request 18-002 for Revision of the Emergency Plan, dated October 31, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18309A320).

2.

McCool, T. P., Vistra Energy, letter to U.S. Nuclear Regulatory Commission, Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Response to Request for Additional Information Regarding License Amendment Request (LAR)18-002 for Revision of the Emergency Plan and Supplement to LAR 18-002, dated March 28, 2019 (ADAMS Accession No. ML19155A309).

3.

McCool, T. P., Vistra Energy, letter to U.S. Nuclear Regulatory Commission, Comanche Peak Nuclear Power Plant Docket Nos. 50-445 and 50-446, Response to Supplemental Request for Additional Information Regarding License Amendment Request (LAR)18-002 for Revision of the Emergency Plan and Supplement to LAR 18-002, dated June 3, 2019 (ADAMS Accession No. ML19156A370).

4.

U.S. Nuclear Regulatory Commission, Emergency Planning and Preparedness for Nuclear Power Reactors, Regulatory Guide 1.101, Revision 2, dated October 1981 (ADAMS Accession No. ML090440294).

5.

U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Revision 1, dated November 1980 (ADAMS Accession No. ML040420012).

6.

Kahler, R. E., U.S. Nuclear Regulatory Commission, letter to Susan Perkins-Grew, Nuclear Energy Institute, Alternative Guidance for Licensee Emergency Response Organizations, dated June 12, 2018 (ADAMS Accession No. ML18022A352).

7.

U.S. Nuclear Regulatory Commission, 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).

Principal Contributor: E. Robinson, NSIR Date: November 4, 2019

ML19267A018

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