ML22292A258

PDEP-EAL Amendment RAI

ML22292A258
Person / Time
Site:	Palisades
Issue date:	10/31/2022
From:	Marlayna Vaaler Doell Office of Nuclear Material Safety and Safeguards
To:	Fleming J Holtec
M. V Doell, NMSS/DUWP 415-3178
References
EPID L-2022-LLA-0099
Download: ML22292A258 (2)

Text

REQUEST FOR ADDITIONAL INFORMATION RELATED TO A PROPOSED LICENSE AMENDMENT TO RENEWED FACILITY OPERATING LICENSE NO. DPR-20 CHANGES TO THE EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME HOLTEC DECOMMISSIONING INTERNATIONAL, LLC PALISADES NUCLEAR PLANT DOCKET NO. 50-255 By application dated July 12, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22193A090), Holtec Decommissioning International, LLC (HDI) submitted a license amendment request for the Palisades Nuclear Plant (PNP) to revise the PNP Emergency Plan and Emergency Action Level (EAL) scheme to reflect the permanently shutdown and defueled condition. The proposed changes were submitted to the U.S. Nuclear Regulatory Commission (NRC) for approval prior to implementation, as required under Paragraph 50.54(q)(4) of Title 10 of the Code of Federal Regulations (10 CFR) and 10 CFR Part 50, Appendix E, Section IV.B.2.

The proposed PNP Permanently Defueled Emergency Plan (PDEP) and Permanently Defueled EAL scheme are commensurate with the significantly reduced risk associated with the spent fuel stored in the PNP spent fuel pool after it has sufficiently decayed such that the radiological impact of accidents is not expected to result in radioactive releases that exceed the U.S. Environmental Protection Agency Protective Action Guidelines beyond the PNP site boundary. The proposed amendment would revise the PNP PDEP and the Permanently Defueled EAL scheme to be consistent with the proposed approval of associated emergency preparedness and planning exemptions, which are under review by the NRC staff.

The following is a request for additional information (RAI) to facilitate the technical review of the proposed PNP PDEP and the Permanently Defueled EAL scheme changes being conducted by the NRCs Division of Preparedness and Response, Reactor Licensing Branch staff. Timely and accurate response to this RAI is requested in order to continue the staffs review of the PNP PDEP and the Permanently Defueled EAL license amendment request.

Enclosure

RAI 1

Requirement:

10 CFR 50.47(b)(15), as proposed to be exempted in the HDI Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E, dated July 11, 2022 (ML22192A134), states: Radiological emergency response training is provided to those who may be called on to assist in an emergency.

Associated guidance in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (FEMA-REP-1), as modified by NSIR/DPR/ISG-02, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants, Evaluation Criterion O.3, states:

Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross First Aid, CPR, AED for Lay Responders or equivalent.

Issue:

HDI does not provide information related to if courses equivalent to Red Cross First Aid, CPR, or AED are offered for Responders or equivalent.

Request:

Please provide what level of training is offered to personnel assigned to respond to emergencies at PNP.