ML22202A464

Emergency Plan Safety Evaluation

ML22202A464
Person / Time
Site:	Beaver Valley
Issue date:	06/29/2022
From:	Lashley P Energy Harbor Nuclear Corp
To:	Ballard B NRC/NRR/DORL/LPL1
Ballard B
References
Download: ML22202A464 (2)

Text

Ballard, Brent

From: Lashley, Phil H <phlashley@energyharbor.com>

Sent: Wednesday, June 29, 2022 1:23 PM To: Ballard, Brent <Brent.Ballard@nrc.gov>

Cc: McCreary, Dave M <dmccreary@energyharbor.com>; Osting, Steven J <sjosting@energyharbor.com>

Subject:

[External_Sender] BVPS Emergency Plan Safety Evaluation

Brent,

While reviewing the safety evaluation supporting the recent emergency plan changes at Beaver Valley Power Station, our staff noticed a couple of erroneous statements, which are listed below for your consideration.

Page 6 SER under major Functional areas The current Beaver Valley EPP activates the TSC and OSC at the declaration of an Alert or higher ECL and activates the EOF and JIC at the declaration of a Site Area Emergency or higher ECL. Energy Harbor proposes to activate the TSC, OSC, EOF, and JIC within 60 minutes of declaring an Alert or higher ECL.

Although activation of the EOF and JIC would not be required until the declaration of a Site Area Emergency or higher ECL is in effect per the guidance in the Revised Table B-1, the proposed ERO staffing changes to the Beaver Valley EPP require the TSC, OSC, EOF, and JIC to activate at the declaration of an Alert or higher ECL.

CORRECTION:

The proposed change indicates that the TSC, OSC, and EOF are activated within 60 minutes and the JIC will be staffed at alert or higher classification.

(reference proposed EPP-section 6.2.3).

Page 8 SER under Offsite Dose Assessment The current Beaver Valley EPP maintains an on-shift dose assessment function by an on-shift chemistry technician.

CORRECTION:

Current on-shift dose assessment is performed by a Radiation Protection Technician. The next paragraph (on page 9) lists this correctly as the on-shift RP Technician is responsible for Dose Assessment.

Page 10 under Onsite (out of plant) and In-Plant Surveys The first paragraph -last sentence: These additional RP technicians perform all of the required RP functions, which include onsite (out of plan) and in-plant surveys, as well as protective actions (in-plant).

CORRECTION:

Parenthesis item should state (out of plant) not out of plan

Page 14 under major Functional Area: Protective Actions (In-Plant)

First paragraph correctly lists The Revised Table B-1 recommends one RP Technician per unit for a multi-unit site, and three additional RP Technicians within 60 minutes and three additional RP Technicians within 90 minutes of an Alert or higher classification, respectively.

Second to last paragraph on page 14 The NRC staff finds the improved use of technology regarding access control and electronic area radiation monitoring, and the staffing of two on-shift RP technicians, two RP technicians augmenting in 60 minutes, and two RP technicians augmenting in 90 minutes will not result in a loss of function or impact to the timing of the performance of protective actions and are consistent the guidance in the Revised Table B-1 and are acceptable.

1 CORRECTION:

It should state one RP Technician per unit for a multi-unit site, and three additional RP Technicians within 60 minutes and three additional RP Technicians within 90 minutes of an Alert or higher classification (reference paragraphs 3.2.4 and 3.2.6 in Enclosure and Attachment 2 (EPP) Table 5.1)

These items are brought to your attention for consideration if a corrected safety evaluation should be issued.

Respectfully,

Phil H. Lashley Manager, Fleet Licensing (330) 696-7208

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