ML20073R753

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Independent Spent Fuel Storage Installation (ISFSI) - APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements
ML20073R753
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 03/13/2020
From: Rash B
Arizona Public Service Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
102-08074-BJR/MSC
Download: ML20073R753 (16)
v • d • e


Text

10 CFR 50.90 10 CFR 50.54(q)

BRUCE 3. RASH Vice President, Nuclear Qaps Engineering Palo Verde Nuclear Generating Station 102-08074-BJR/MSC P.O. Box 52034 March 13, 2020 Phoenix, AZ 85072 Mall Station 7602 ATTN: Document Control Desk Tel 623.393.5102 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Docket Nos. STN 50-528, 50-529, 50-530 and 72-44 Renewed Operating License Nos. NPF-41, NPF-51, NPF-74 APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements By letter number 102-07981, dated October 18, 2019 (Agencywide Documents Access and Management System Accession Number ML19291F735), Arizona Pubiic Service Company (APS) submitted a license amendment request (LAR) to change the Paio Verde Nuciear Generating Station (PVNGS) Emergency Pian staffing requirements.

The Nuclear Regulatory Commission (NRC) staff requested additional information to compiete their review with regard to the proposed changes for the PVNGS Emergency Pian.

A clarifying phone caii was held between the NRC staff and APS on February 12, 2020, to discuss the additional information needed. The APS response to the request for additional information is provided in the enciosure to this letter. The response due date is March 17, 2020.

No new commitments are being made in this submittal. If you have any questions about this request, piease contact Matthew S. Cox, Section Leader, Licensing, at (623) 393-5753.

I deciare under penalty of perjury that the foregoing is true and correct.

Executed on March 13, 2020 (Date)

Sincerely, hj. J^c BJR/MSC A member of the STARS Alliance LLC Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

102-08074-BJR/MSC ATTN: Document Control Desk U. S. Nuclear Regulatory Commission APS Response to Request for Additionai Information for Changes to PVNGS Emergency Plan Staffing Requirements Page 2 Enciosure: APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements cc: S. A. Morris NRC Region IV Regionai Administrator S. P. Lingam NRC NRR Project Manager for PVNGS C. A. Peabody NRC Senior Resident Inspector for PVNGS

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..jgrL Enclosure k- APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements Table of Contents Enclosure - APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements Attachment 1 - PVNGS Radiation Protection by Function K

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Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements By application dated October 18, 2019 (Agencywide Documents Access and Management System Accession No. ML19291F735), Arizona Public Service Company (APS, the licensee) requested changes to the Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde, PVNGS) Emergency Plan pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes would revise the Palo Verde Emergency Plan to change the emergency response organization (ERO) staffing composition for certain ERO positions.

The proposed changes include:

  • Reduction of two on-shift Electrical Maintenance Technician positions;
  • Reduction of one on-shift Maintenance Technician position;
  • Reduction of two on-shift Radiation Protection (RP) Technician positions;

The current Palo Verde Emergency Plan provides for augmentation of ERO positions within 60 minutes of an Alert or greater classification level during normal working hours and within 120 minutes during off hours. These positions include emergency direction and control, engineering support, communications, and radiation protection. The U.S. Nuclear Regulatory Commission (NRC) staff previously found the current Palo Verde ERO augmentation as reasonable based on the extensive on-shift capabilities provided in the Palo Verde Emergency Plan. The proposed Palo Verde Emergency Plan reduces those on-shift capabilities.

PVNGS-RAI-1:

Concerning the Repair Team Activities Functional Area, Section 3.1.5.C, Non-License Operator (NLO) Training, on page 19 of Enclosure, "License Amendment Request Changes to Emergency Plan Staffing Requirements," provides that NLOs may be used for abnormal operating procedure/emergency operating procedure (AOP/EOP) actions and in-plant maintenance. In-plant maintenance would be under the oversight of the on-shift maintenance technicians as needed. The Emergency Plan (EP) Change Assessment for Section 3.2.9, "EP Function: Repair Team Activities," on page 39 of the Enclosure further provides that the current Palo Verde Emergency Plan allows the Repair Activities function to be performed as a collateral duty.

The NRC staff understands that NLOs are trained and qualified to perform a wide range of tasks associated with AOP/EOP actions, maintenance support activities such as pulling fuses or lifting/landing leads, and various additional tasks as governed by operations procedures with training that meets the requirements of 10 CFR 50.120, Training and qualification of nuclear power plant personnel.

a. Please explain what training, consistent with 10 CFR 50.120, provides the NLOs with the knowledges, skills, and abilities to perform maintenance activities that are not specifically :

identified in operations procedures, such as AOPs/EOPs.

b. If the NLOs are trained and proficient as maintenance technicians, please explain how oversight will be provided by the proposed on-shift maintenance staffing. The response should describe the training and qualifications of the on-shift maintenance staff to provide oversight.
c. With the footnote "1" assigned to the personnel designated on-shift for the function of Repair Team Activities, it could be interpreted that NLOs would be able to fill these positions on-shift in lieu of qualified maintenance personnel. Please explain whether qualified maintenance personnel will be assigned to these positions on-shift at all times.

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements APS Response to RAI-1:

a. Palo Verde Nuclear Generating Station (PVNGS) utilizes the Non-Licensed Operators (NLOs) to perform Severe Accident Management Guidelines (SAMGs), Extensive Damage Management Guidelines (EDMGs), and Diverse and Flexible Mitigation Capability (FLEX) procedures. This is in addition to the variety of operational maintenance activities associated with AOP/EOP steps. The tasks associated with those actions are contained within the accredited training program for NLOs.

The current PVNGS Emergency Plan has three on-shift electrical maintenance technicians, two on-shift mechanical maintenance technicians and one on-shift instrumentation and control (I&C) maintenance technician to handle a broad range of maintenance during the initial phase of the emergency. The industry has gained insights from plant performance and accident analysis to understand the primary repair activities that are needed to -I protect the core are associated with the emergency core cooling system (ECCS) and i)-i.

functionally recovering critical safety equipment. Due to the redundant nature of those systems and the imposed requirements on protecting one train whenever maintenance is

-."i being performed on the other train, likely repairs that are needed are more narrowly focused than previously thought when the PVNGS Emergency Plan staffing was originally developed. The technical staffing basis from NUREG-0654, Criteria for Preparation and ll.

Evaiuation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 2, describes the ECCS focus. A

' I The PVNGS proposed Emergency Plan has the principle areas of need for on-shIft emergency maintenance as 1) restoration or maintaining emergency core cooling and 2) restoration or functional recovery of critical safety functions (CSFs) as determined by plant operations (AOP/EOPs, etc.). The NLOs are trained to perform maintenance activities needed to support day-to-day operating tasks, AOP/EOPs, FLEX, SAMG and EDMG steps (included within the NLO Master Task list which is part of the NLO accredited training program). On-shift maintenance technicians (mechanical, electrical and I&C) would be in place for those expanded repair actions needed for CSF restoration. The capability of on-shift NLOs and the on-shift mechanical, electrical and I&C technicians ii- ensure repair activities associated with restoration of CSFs (to include ECCS) can 5 progress until augmentation at the 60 or 120 minute timeframe.

One mechanical, one electrical and one I&C maintenance technician along with the NLOs would be adequate for the likely repairs needed to maintain ECCS and act on CSF equipment challenges. In the proposed PVNGS Emergency Plan, PVNGS augmented with additional maintenance resources (one of each of the mechanical, electrical and I&C maintenance technicians) as minimum staff in the Operations Support Center (OSC) above that included in NUREG-0654, Revision 2, guidance.

Activities that could potentially be required for NLOs to perform during the initial phase of an emergency would include manual operation of valves, racking in breakers to restore power to an ECCS pump (restoring a system to service), potential sampling of systems, adding oil, the ability to read station prints, installation of temporary gauges to support system monitoring, restoring power to coping loads (FLEX and FLEX plus equipment),

implementation of SAMG and EDMG actions. Non-Licensed Operator training is in place to support performance of these activities.

An AOP/EOP review was performed regarding the maintenance activities that could be needed in the first 120 minutes of an emergency. The following is a list of those tasks and the responsible work group(s) to perform them:

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements

  • Electrical Maintenance Inspect and troubleshoot medium voltage circuit breaker if breaker trips or fails to close (NLOs are trained on racking in and out breakers minimizing the need for troubleshooting and inspection. Non-Licensed Operators are trained to reset relays on breakers).

I&C Maintenance Use troubleshooting job-aids to diagnose failure of annunciator section

[Reactor Operators (ROs) perform this task which is part of the qualification process and their Job Qualification Card (JQC)].

Install temporary recorder for plant monitoring Collect thermocouple data in event of reactor vessel level monitoring iirt-. system (RVLMS) failure j--' .

Additionally, it should be noted that PVNGS uses an "all call" augmentation process for the entire ERO which ensures adequate resources are augmented and available, if needed, to respond to the emergency.

b. Non-Licensed Operators are not trained as maintenance technicians, but they are I'!.: qualified for maintenance activities that would be necessary on-shift to support AOP/EOP actions in addition to other activities (FLEX, EDMG, SAMG, etc.). For those activities NLOs are not qualified to perform, on-shift maintenance personnel would be available to perform the repair or provide the needed guidance and oversight to the NLOs to perform the work consistent with the dependent worker program. On-shift maintenance technicians are trained for dependent worker assignments and as such, are capable to provide guidance and oversight. Maintenance technicians receive this in their initial training course, and it is a practice at the station to support maintenance activities during outages and on-line periods.
c. A qualified maintenance technician will be assigned on-shift at all times (PVNGS will not use a NLO to perform the function of Repair Team Activities). The application of footnote "1" was an oversight in the license amendment request for the function of Repair Team Activities. The revised table for the function of Repair Team Activities with footnote "1" removed from the Mechanical Maintenance Technician, Electrical Maintenance Technician and I&C Maintenance Technician is shown as follows:

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Pian Staffing Requirements EP Function: Repair Team Activities - On-shift Minimum Staff (Revised)

Current Emergency Plan, Table 1 Proposed Emergency Plan, Table 1 NUREG-0654, Revision 2, Guidance (2) Mechanical Technicians (1) Mechanical Maintenance Operations Staffs (May be provided by other Technician personnel assigned other ^Other personnel may be functions.) (1) Electrical Maintenance assigned this function if Technician no collateral duties are (3) Electrical Technicians assigned to an individual (May be provided by other (1) I&C Maintenance Technician that are beyond the personnel assigned other capability of that functions.) (12) Plant Equipment individual to perform at Operators^ any given time.

(1) I&C Technician (May be provided by other ^Other personnel may be >>I personnel assigned other assigned this function if no functions.)

collateral duties are assigned to V (12) Plant Equipment an individual that are beyond the Operators capability of that individual to perform at any given time.

r PVNGS-RAI-2:

The current on-shift RP staffing includes 3 RP Technicians, 1 Radiation Monitoring (RM)

Technician, 1 RM or RP Technician, 1 Survey Qualified Position, and 1 Radiation Field Assessment Team Driver. These RP positions are currently in addition to a RP Monitor/Group Lead on-shift position. The NRC staff found the original extension in augmentation time for RP staffing was based on the total on-shift RP staffing of eight RP Technicians. This RP Technician staffing was later modified and was compensated for by providing two/three RP task trained individuais that may, or may not be, fully qualified RP Technicians.

As proposed, the PVNGS Emergency Plan does not provide 3 RP Technicians within 60 minutes or an additional 3 RP Technicians within 90 minutes of the declaration of an Alert or greater classification level as provided in Table B-1, "Emergency Response Organization Staffing and Augmentation Plan," of NUREG-0654/FEMA-REP-1 (NUREG-0654), Revision 2. The staffing provided in Table B-1 is based, in part, on radiation protection and improvements, such as those provided by Section 3.1.6, "Radiation Protection Improvements," of application Enclosure 1; however, there is no specific justification for the removal of the non-RP trained personnel assigned RP functions from the on-shift staffing.

a. Please provide further justification for the removai of the non-RP trained personnel assigned RP functions from the on-shift staffing. Specifically, what functions were being performed until augmentation occurred and what are the impacts to the Radiation Protection function.
b. Please explain what plant specific conditions that are unique to Palo Verde support extending the ERO response time of 3 RP Technicians from within 60 minutes and an additional 3 RP Technicians from within 90 minutes of the declaration of an Alert to 120 minutes of the declaration of an Alert or greater classification level during off hours or revise accordingly.

APS Response to RAI-2:

a. The RP or RM Technician (in-plant survey). Survey Task Qualified Technician (offsite survey) and RM Technician (effluent monitoring) are no longer segregated in the proposed on-shift ERO RP staffing. Palo Verde Nuclear Generating Station will only be

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements using RP qualified technicians as on-shift RP ERO. The three onsite RP technicians are being used for access controi, job coverage, and in-piant survey. Through the use of eiectronic access control, dosimetry with dose and dose rate readout, and the use of teiemetry (providing dose and dose rate readout in the Control Room and RP work area) for the on-shift ERO, three fully qualified RP Technicians will be adequate to maintain the function until augmentation. Through improved technology in the RP area, those prior manual functions can be done remotely without impacting the ability of the other three RP technicians to perform their required tasks.

During normal plant operations where maintenance activities are being performed on plant safety systems [impact a limiting condition for operation (LCD) ten days or less],

balance of plant (BOP) redundancy or conditional single point vulnerabilities (SPV) are typically worked around the clock with additional station personnel to return the system or component back to service as soon as practical within the LCO out of service time. If the critical maintenance involves work on a primary system, additional RP support is also provided around the clock.

See Attachment 1 for further discussion of the RP functions.

b. Palo Verde Nuclear Generating Station specific use of RP technology allows the three onsite RP technicians used for access control, job coverage and in-plant survey as well as the additional RP Technician and Radiological Field Assessment Team (RFAT) driver for offsite monitoring, to adequately maintain the radiological safety function until the OSC is staffed with augmented maintenance and RP resources. The on-shift RPs have improved resources that allow for a more efficient use of their time performing in-plant surveys, access control and job coverage [improved Radiation Monitoring System (RMS),

telemetric dosimetry, radio communications, and electronic access control]. The use of additional augmented RPs is associated with the increased demand for Repair Team Activity associated with augmentation. Through the use of electronic access control, dosimetry with dose and dose rate readout, and the use of telemetry (providing dose and dose rate readout) for the on-shift ERO (NLO, Maintenance and RP), three fully qualified RP Technicians will be adequate until resources are augmented at the 60 or 120 minute timeframe. See Attachment 1 for further discussion of the RP functions.

PVNGS-RAI-3:

Section 3.2.11, "EP Function: Field Monitoring Teams," of the Enclosure includes 1 RP Technician and Radiation Field Assessment Team Driver. APS provides that the licensee has manned an additional RP Technician on-shift to perform the Field Monitoring function until augmented. However, the licensee is also proposing to remove two individuals who were qualified to perform certain RP tasks. As such, the licensee is proposing to replace three individuals, one of which may have been a RP Technician, with one RP Technician. The NRC staff could not identify a technical evaluation supporting this change.

a. Please provide further justification that supports replacing three RP personnel with one RP Technician. This justification should discuss the functions/tasks performed by the RP personnel proposed for removal as on-shift staffing positions.

Please explain how the proposed RP staffing supports performance of the Field Monitoring EP Function without impacting the capability to perform the Radiation Protection Function.

If the licensee proposes to use task qualified personnel to perform the Field Monitoring EP Function, please explain who will provide RP oversight as required.

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Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements APS Response to RAI-3:

a. The RP or RM Technician previously designated for in-plant survey and the Survey Task Qualified Technician previously designated for offsite survey are being replaced with the t fourth RP Technician on-shift and can function as either onsite or offsite field monitoring along with a dedicated RFAT driver. The RM Technician (effluent monitoring) is being replaced through the use of Improved technology in that effluent monitor readout is available on workstations in the RP work area, Control Rooms, and in each Emergency Response Facility (ERF). The in-plant survey function when the RP technician is needed offsite is backfilled with one of the onsite RP Technicians, as necessary. The use of the various improved monitoring technologies in place (dose and dose rate telemetry, electronic dosimetry, improved access to radiological data) allows for that to take place.

See Attachment 1 for further discussion of the RP functions.

b. Palo Verde Nuclear Generating Station will only be using fully qualified RP Technicians as on-shift RP ERO in lieu of non-RP or task qualified responders. The three onsite RP technicians are being used for access control, job coverage, and in-plant survey while the fourth RP technician along with the dedicated RFAT driver will fulfil the field monitoring function. Through the use of improved technology (electronic access control, dosimetry with local dose and dose rate readout, and the use of telemetry providing dose and dose K'V rate readout to any RP workstation and the Control Room) for the on-shift ERO, three fully qualified RP Technicians will be adequate to maintain the RP function of access control, in-plant survey and job coverage until additional RP Technicians are augmented at the 60 or 120 minute timeframe. See Attachment 1 for further discussion of the RP functions.
c. Palo Verde Nuclear Generating Station will not use task qualified non-RP personnel beyond the RFAT driver for field monitoring. A fully qualified RP Technician will be used for field monitoring who reports back to the on-shift Radiation Protection Monitor (RPM),

negating the need for oversight.

PVNGS-RAI-4:

APS provided that the Engineering Director will be removed from a Palo Verde Emergency Plan minimum staffing position to a position controlled by an emergency plan implementing procedure (EPIP). Additionally, the licensee proposed to move the Engineering Manager position from the Palo Verde Emergency Plan to a position controlled by an EPIP.

a. Please provide a justification, in greater detail, that supports removing the Engineering Director as a minimum staff augmentation position. The NRC staff does understand that this position is not included in NUREG-0654, Revision 2, but could not determine whether the proposed change could impact the performance of the Engineering EP Function.
b. Please provide a justification, in greater detail, that supports removing the Engineering Manager from the Palo Verde Emergency Plan. The NRC staff does understand that this position is not included in NUREG-0654, Revision 2, but could not determine whether the proposed change could impact the performance of the Engineering EP Function.

The proposed Electrical/Instrument and Control Engineer, Reactor Analyst, and Mechanical Engineer will continue to report to the Engineering Manager. In the current Palo Verde Emergency Plan, the Engineering Manager reports to the Engineering I Director. Please explain how the proposed minimum staff positions for the Electrical/Instrument and Control Engineer, Reactor Analyst, and Mechanical Engineer functions can be performed when the Engineering Manager and Engineering Director Ilf positions are not Palo Verde minimum staff positions or revise accordingly.

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements APS Response to RAI-4:

a. The Engineering Director is located in the Emergency Operations Facility (EOF) and coordinates the engineering performed in the Technical Support Center (TSC) with the EOF team. That coordination serves as a conduit for information from the TSC and does not involve any direction or control of the engineering function onsite. The absence of the Engineering Director will not impact the Engineering function in the TSC and there are sufficient communication conduits between facilities for the transfer of information, rendering the Engineering Director position in the EOF redundant and unnecessary for the PVNGS Emergency Plan.
b. The current PVNGS Emergency Plan has the TSC Engineering Manager coordinate the TSC 3 engineering function and interface with external engineering support once in place. The TSC Engineering Manager utilizes the engineering staff for the performance of the function. The absence of the TSC Engineering Manager does not negate or delay the engineering function as each position has position checklists for their activities. Those checklist products would be provided directly to the TSC Emergency Coordinator until the TSC Engineering Manager arrives in the facility.
c. The proposed minimum staff positions for the Electrical/I&C Engineer, Reactor Analyst, and Mechanical Engineer functions are not altered prior to the TSC Engineering Manager
r. arrival in facility. The functions would use their procedural checklists and report directly to the TSC Emergency Coordinator until the TSC Engineering Manager arrived onsite.

PVNGS-RAI-5:

Section 3.2.7, "EP Function: Engineering," of the Enclosure implies that every shift technical advisor (STA) is trained and proficient as an STA, an electrical engineer, a mechanical engineer, and a maintenance supervisor for multiple disciplines. Although STAs attend a training program that meets the systematic approach to training requirements of 10 CFR 50.120(b)(2)(iii), "Shift technical advisor," they are not typically trained pursuant to the training requirements of 10 CFR 50.120(b)(2)(ix), "Engineering support personnel".

a. Please provide further justification that supports the STAs training and proficiency to perform the mechanical and the electrical/instrument and control engineer function or revise accordingly.
b. Please provide further justification that supports the STAs training and proficiency to perform mechanical, and electrical/instrument and control maintenance and troubleshooting in accordance with existing Palo Verde maintenance procedures or revise accordingly.
c. If the Palo Verde STAs are currently qualified as electrical engineers, mechanical engineers, and maintenance supervisors, please explain how these additional training and proficiencies are/will be documented and maintained in the Palo Verde Emergency Plan.

APS Response to RAI-5: i

a. The current PVNGS Emergency Plan has the unaffected unit STA provide mechanical and electrical/I&C engineering function support until augmented in the TSC. The STAs are degreed engineers with a senior reactor operator (SRO) level of knowledge who are trained and qualified for print reading and troubleshooting using existing plant procedures. The STA training is provided as part of the Operations accredited training -

program. The proposed change does not alter that function being performed by the unaffected unit STA.

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements

b. The STAs are not qualified to perform maintenance, but they are trained and qualified to provide mechanical and electrical support for troubleshooting using existing plant procedures utilizing their SRO level of knowledge. The troubleshooting responsibility for the STAs is in the PVNGS Emergency Plan.
c. The STAs are degreed engineers with a SRO level of knowledge, they are not qualified as engineers as part of the station Engineering training program. Shift Technical Advisors are not qualified to perform maintenance, but they are qualified for troubleshooting using existing plant procedures. Their SRO level of knowledge of the plant and training on the troubleshooting procedure has the STAs capable of performing troubleshooting prior to augmentation. The troubleshooting responsibility for the STA is in the PVNGS Emergency Plan.

PVNGS-RAI-6:

Section 3.2.10, "EP Function: Repair Team Activities," of the Enclosure provides that the Shift Manager/Emergency Coordinator position is used for the Repair Team Supervisor position. Additionally, this section states that under the Palo Verde Maintenance Program, experienced craft technicians act as lead technicians on back shifts. Although this statement 4 could imply that lead craft technicians are currently available on back shifts, the NRC staff could not identify any lead craft technicians as required ERO positions in either the current or proposed Palo Verde Emergency Plans until 120 minutes after the declaration of an Alert or 1

greater classification level during off hours.

a. Please clarify whether lead craft technicians are provided on back shifts at Palo Verde.
b. Please explain how the proposed reduction in qualified maintenance personnel on-shift, and reliance on Shift Manager/Emergency Coordinator position in the Repair Team Supervisor position, supports plant maintenance and troubleshooting in accordance with Palo Verde procedures to effectively perform the Repair Team Activities function until augmented.
c. Please explain what plant specific conditions that are unique to Palo Verde support extending the ERO response time of the OSC Manager from within 60 minutes and two OSC Repair Team Coordinators from within 90 minutes of the declaration of an Alert to 120 minutes of the declaration of an Alert classification level during off hours or revise accordingly.

APS Response to RAI-6:

a. While not titled as a lead technician, craft technicians are provided on back shift and are trained and qualified within their respective crafts (I&C, Electrical, and Mechanical) and have completed the initial training program. The initial training program ensures the knowledge and skills to complete the proper station processes, procedures, expectations, and activities for a task that may be assigned to lead craft technicians in support of implementation of the emergency plan. This includes knowledge and training of the requirements of dependent workers, and completing their tasks as qualified craft personnel. Non-Licensed Operators would be considered dependent workers for work they may not be trained or qualified to perform and the on-shift maintenance technicians would provide the needed oversight and guidance based on the difficulty and sensitivity of the work.
b. The current PVNGS Emergency Plan has the Shift Manager/Emergency Coordinator responsible for on-shift response until augmentation is complete. This is consistent with 8

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements day-to-day plant activities for any emergent maintenance. The Shift Manager has the support of the STA for troubleshooting, along with the NLOs and on-shift maintenance staff. Additionally, an unaffected unit Shift Manager is avaiiable to assist in the control of repair activities, if needed.

The industry has gained insights from plant performance and accident analysis to understand the primary repair needs to protect the core are associated with the ECCS system and those actions needed to functionally recover critical safety equipment. Due to the redundant nature of those systems and the imposed requirements on protecting one train whenever maintenance is being performed on the other train, likely repairs that are needed are more narrowly focused than previously thought when the PVNGS Emergency Plan staffing was originally developed (the original guidance was not specific to what maintenance was required for the on-shift staff leading to a broader focus).

The technical staffing basis from NUREG-0654, Revision 2, describes that change in focus regarding maintenance. One Mechanicai, one Electrical and one I&C Maintenance Technician along with the NLOs would be adequate for the likely repairs needed to maintain ECCS and act on CSF equipment challenges. During normal plant operations where maintenance activities are being performed on plant safety systems (impact a LCO ten days or less), balance of plant (BOP) redundancy or conditional single point vulnerabilities (SPV) are typicaliy worked around the clock with additional station personnel to return the system or component back to service as soon as practical within the LCO out of service time. If the critical maintenance involves work on a primary system, additional RP support is also available around the clock.

In the proposed PVNGS Emergency Plan, PVNGS committed to augmenting additional maintenance resources at the 60 or 120 minute timeframe (one of each of the mechanical, electrical and I&C maintenance technicians) as minimum staff in the OSC above that included in NUREG-0654, Revision 2, guidance.

It should be noted that PVNGS uses an "all call" augmentation process initiated for an Alert or higher emergency for the entire ERO which ensures adequate resources are available, if needed, to respond to the emergency.

c. The current PVNGS Emergency Plan augments an OSC Manager along with the additional plant staff for the OSC at the 60 or 120 minute timeframe. The Shift Manager/Emergency Coordinator manages on-shift resources until augmentation in a manner similar to day-to-day activities. Paio Verde Nuclear Generating Station has three operating units with a qualified Shift Manager in each unit. A Shift Manager from an unaffected unit is available to support repair team oversight until augmentation, if needed.

Staffing for the OSC Manager is augmented the same time as the OSC staff and Repair Team Coordinators. During normal working hours those personnel are onsite and are functioning within the OSC, managing the additional manpower within that facility. After hours, the remaining resources do not arrive onsite until 120 minutes and as such, OSC Managers and Repair Team Coordinators will be In place to manage those resources. In the timeframe prior to augmentation, the Shift Manager/Emergency Coordinator would manage onsite resources as they do every day. Routine activities onsite would transition from the normal plan of the day activities to critical emergency activities.

It should be noted that PVNGS uses an "all call" augmentation process initiated for an Alert or higher emergency for the entire ERO which ensures adequate resources are available, if needed, to respond to the emergency.

I tiiimiit-Tiiiiiiii.vi ....

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements PVNGS-RAI-7:

Section 3.2.12, "EP Function: Media Information," of the Enclosure provides that the Palo Verde Communication Department provides for the Joint Information Center (JIC) functions until the JIC is activated and turnover of responsibility occurs. It further states that the activation time provides for a specific timeframe in the Emergency Plan to fill the JIC minimum staff positions and sooner than that stipulated in the draft guidance.

Please clarify how the JIC is able to activate and receive the responsibility for JIC functions with i only the JIC Manager designated as the minimum staffing to activate the JIC.

APS Response to RAI-7:

The current PVNGS Emergency Plan does not specify a minimum staff or augmentation time for the JIC. The JIC is; however, activated at the same time as the ERO for all other facilities (Alert or higher). That augmentation is within 60 minutes of the declaration of an Alert or higher emergency during normal working hours and 120 minutes during non-working hours.

The JIC is co-located with the Emergency Operations Facility. The JIC Manager, once in facility, will have the information regarding the emergency available to the EOF and can provide that information to the media until additional personnel (PVNGS and State and Local government) arrive in the JIC. Palo Verde Nuclear Generating Station and APS Communications have resources available to support media inquiries on a day-to-day basis.

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y- ^. I ,1 ri, 1i:

r Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements Attachment 1 Attachment 1 PVNGS Radiation Protection by Function Discussion r The current PVNGS Emergency Plan has eight individuals on-shift that are immediately available for performing the RP function during normal working hours until off-hour augmentation occurs at 120 minutes (see table below). Of those eight, two are non-RP qualified individuals, the Survey Qualified Technician and the RFAT Driver.

Below Is a comparison of the current PVNGS Emergency Plan against the proposed PVNGS Emergency Plan, by function, with the improvements listed in the far right column.

RP Function Matrix Current Proposed RP Function Emergency Emergency Plan Process Improvements Pian Chanqe RP Coverage, 3 RP Technicians 3 RP Technicians

  • Electronic Pocket dosimetry In-Plant Survey,
  • On-shift ERO Telemetry [dose/dose rate Access control monitoring via graphical electronic dosimetry display system (GEDDS)]

available in Control Room, RP Work Area and ERFs for the Auxiliary, Radiological Waste and Fuel Building

  • Use of fully qualified RP Technicians
  • Electronic Radiation Work Permit (RWP)
  • Egress monitoring for workers and tools Radiation/Effluent 1 Radiation None RMS readout in Control Room, RP Work Monitoring Monitoring (RM) area, ERFs, and on network workstations Technician^ obviate need for RM Technician.

1 RM or RP ^

  • Use of fully qualified RP Technicians Onsite Surveys 1 RP Technician Technician (serves as onsite or
  • Dedicated RFAT vehicles offsite field
  • Onsite survey can be back filled with Offsite Field 1 Survey Qualified monitoring, as one of on-shift RP Technicians based on Monitoring Position^ needed) efficiencies gained via technology 1 Radiation Field 1 Radiation Field No change Assessment Team Assessment Team Driver^ Driver^

RP Supervision 1 RP 1 RP Monitor/Group

  • Effluent monitoring via plant and Dose Monitor/Group Lead information system (PI) in Control Assessment Lead Room and RP work area
  • RP Supervision continuity from on-shift to the OSC (no turnover)

Total on-shift 8 6 Notes:

1. Assigned to RPM for monitoring RMS
2. Water Resources Facility plant technician

Enclosure APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements Attachment 1 With the increases in the use of technoiogy in the area of Radiation Protection, a reduction of two on-shift RP personnel is considered appropriate (survey qualified technician and Radiation Monitoring Technician). In the early phase of an accident, an offsite monitoring team is less of a focus as long as it can be augmented with 60 minutes. The technical staffing basis from NUREG-0654, Revision 2, describes this point. Due to PVNGS demographics, an additional on-shift qualified RP Technician was added to bridge the gap until the six augmented RP Technicians arrived at 60 or 120 minutes. That RP Technician along with the RFAT driver could be utilized for either onsite out of plant or offsite monitoring.

Improvements in the use of computerized area radiation and telemetry based personnel monitoring (dose and dose rate) capable of readout in a variety of locations (RP work area.

Control Rooms and ERFs) along with improved emergency procedures, electronic dosimetry with self-reading capability (with dose and dose rate alarms), and electronic access control allow the three on-shift technicians to perform onsite surveys if the fourth RP Technician is dispatched offsite. The use of electronic pre-made radiation work permits for emergencies allow for improved performance and use of resources. The RP on-shift ERO responders are qualified RP Technicians so the need for non-RP personnel is no longer needed beyond the RFAT driver. The function that the Radiation Monitoring Technician performs in the effluent monitoring area is no longer necessary with the improvement to the plant RMS and PI. Additionally, RP Supervision is on-shift (initially in Control Room and transitions to OSC when EOF assumes the Dose Assessment function). This position checks the effluent monitors as they relate to dose assessment. By utilizing the RPM initially and in the OSC, continuity of the event is ensured and increases the efficiency of the RP response function by not requiring a turnover to the OSC.

Through these improvements along with the industry learnings from past emergencies (as denoted in the technical staffing basis from NUREG-0654, Revision 2) fewer RP resources were needed in the initial phase of the emergency. Palo Verde Nuclear Generating Station, being a remote plant whose population within the emergency planning zone is very small (under 10,000 consolidated to the north and east of the plant) and the plant employees living in Phoenix and the surrounding communities required the functional capability on-shift to be sustained for a greater period. Palo Verde Nuclear Generating Station added an additional RP Technician (can be used for either onsite or offsite field monitoring) to bridge the timeframe until augmented resources arrive onsite. The transition still allows the onsite RP functions to continue by leveraging technology and the use of fully qualified RP Technicians. The remainder of the six RP technicians augmented would be immediately available following an Alert or higher emergency during normal working hours and at 120 minutes off hours. The RP functions augmented by those personnel are not needed until the increased repair team personnel called in for the emergency arrive within the OSC. Since the ERO is augmented in an "all call" manner, adequate resources would be onsite to support response activities.

Additionally, site scheduling during normal plant operations where maintenance activities are being performed on plant safety systems that impact a LCO of ten days or less, balance of plant (BOP) redundancy or conditional single point vulnerabilities (SPV) are typically worked around the clock with additional station personnel to return the system or component back to service as soon as practical within the LCO out of service time. If the critical maintenance involves work on il a primary system, additional RP support is also available around the clock. This addition helps ensure the RP Technicians assigned for ERO are not depleted for plant activities as they relate to critical maintenance. i iMytiilMiTiiiilifc Ilfn mi 't i1 I liiifVl'iititfl

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