PNP 2014-091, Supplement to License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times
| ML14343A581 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/09/2014 |
| From: | Vitale A Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2014-091 | |
| Download: ML14343A581 (16) | |
Text
A Entergy Nuclear Operations, Inc.
Entergy Palisades Nuclear Plant Inc.
~ Entergy 27780 Blue Star Memorial Highway Ml 49043-9530 Covert, MI
- Tel 269 764 2000 Anthony J. Vitale President Site Vice President Site PNP 2014-091 December 9, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Supplement to License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times Palisades Nuclear Plant Docket 50-255 License No. DPR-20
REFERENCES:
- 1. Entergy Nuclear Operations, Inc. (END) letter to NRC, PNP 2013-044, License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated June 25, 2013 (ADAMS Accession No. ML113176A405).
ML 31 76A405).
- 2. END, MF2321 PNP Request for Additional NRC email to END, Information (RAI) for License Amendment Request to Revise ERO Staff Augmentation Response Times, dated July 23, 2013 (ADAMS Accession No. No. ML ML13205A163).
13205A 163).
3.
- 3. END letter to NRC, PNP 2013-060, Response to Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated dated August 7, 7, 2013 (ADAMS Accession No. ML1 3220A008).
4.
- 4. NRC email to END, Request for Additional Information - -
Palisades - Proposed Revision to Palisades Site Emergency Plan (SEP) to increase the staff Augmentation response time for certain Emergency Response Organization (ERO) positions from 30 to 60 minutes - MF2321, dated December 16,
- 16, 2013 2013 (ADAMS Accession No. ML13353A042).
PNP 2014-091 Page 2 5.
- 5. ENO letter to NRC, PNP 2014-003, Response to December 16, 2013 Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated February 13, 2014 (ADAMS Accession No. ML ML114044A059).
4044A059).
- 6. NRC email to ENO, Request for Additional Information - -
Palisades - LAR to Revise Emergency Response Response Organization Staff Augmentation Response Times - MF2321, dated May 1,2014 (ADAMS Accession No. ML ML14121A282).
14121A282).
- 7. ENO letter to NRC, PNP 2014-051, Response to May 1, 2014 Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated July 16, 2014.
Dear Sir or Madam:
Operations, Inc.
In Reference 1, Entergy Nuclear Operations, Inc. (ENO) submitted a license amendment request (LAR) to revise the Site Emergency Plan (SEP) at the Palisades (PNP).. The proposed amendment would revise the PNP SEP to increase Nuclear Plant (PNP) the staff augmentation response times for certain emergency response organization (ERO) positions.
In Reference 2, ENO received a request for additional information (RAI) concerning the LAR, and ENO responded to the RAI in Reference 3. ENO received a second RAI in Reference 4, and responded to the second RAI in Reference 5. ENO received a third RAI in Reference 6, and responded to the third RAI in Reference 7.
Following submission of the third RAI response, ENO and the NRC held a conference call on August 19, 2014 to discuss the third RAI response. As a result of the conference call, ENO is hereby submitting a supplement to the LAR that modifies the proposed ERO staffing and augmentation requirements for radiation protection (RP) technicians as described in the LAR (Reference 1) and in the response to the third RAI (Reference 7).
These modifications to RP technician staffing and augmentation requirements affect the Radiological Accident Assessment and Support of two major functional areas (1) "Radiological Operational Accident Assessment" Protective Actions (In-Plant),"
Assessment and (2) "Protective (In-Plant), in PNP SEP Plant Staffing and Augmentation Requirements,"
Figure 5-2, "Plant Requirements, in Attachment 3 of the LAR (Reference 1) and in Attachment 2 of the third RAI response (Reference 7). The Field Monitoring modifications also add a new functional area to SEP Figure 5-2, titled "Field Teams. The changes proposed in the LAR (Reference 1) concerning augmentation Teams."
response times for ERO positions in the remaining major functional areas in SEP Figure 5-2 are not affected by this supplement.
PNP 2014-051 Page 3 Attachment 11 discusses the proposed changes to the ERO staffing and augmentation requirements for RP technicians, and supersedes proposed changes and supporting information provided concerning RP technician staffing and augmentation requirements in previous submittals for this LAR. Attachment 11 also includes a revised no significant hazards consideration for the LAR that reflects the proposed changes to staffing and augmentation requirements for RP technicians which supersedes the no significant hazards consideration submitted in Reference 11 in its entirety. of this supplement contains an updated SEP Figure 5-2 which depicts the proposed changes concerning staffing and augmentation requirements for RP technicians. This figure supersedes the figures previously provided in Attachment 3 of the LAR and in Attachment 2 of the third RAI response.
A copy of this response has been provided to the designated representative of the State of Michigan.
This letter contains no new or revised commitments.
II declare under penalty of perjury that the foregoing is true and correct. Executed on December 9, 2014.
Sincerely, ajv/jse
(
Attachments: 1.
- 1. Changes to Proposed Radiation Protection Technician Staffing and Augmentation Requirements
- 2. Proposed Revision to Palisades Nuclear Plant Site Emergency Plan Pages cc: Administrator, Region III, III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC State of Michigan
ATTACHMENT 11 CHANGES TO PROPOSED RADIATION PROTECTION TECHNICIAN STAFFING AND AUGMENTATION REQUIREMENTS
- 1. Description In Reference 1, Entergy Nuclear Operations, Inc. (ENO) submitted a license amendment request (LAR) to revise the Site Emergency Plan (SEP) at the Palisades Nuclear Plant (PNP). The proposed amendment would revise the PNP SEP to increase the staff augmentation response times for certain emergency response organization (ERO) positions. The proposed amendment included changes to RP technician augmentation response times in the following two major functional areas: (1) "Radiological Radiological Accident Assessment and Support of Operational Accident Assessment Protective Assessment" and (2) "Protective Actions (In-Plant)"
(In-Plant) in SEP Figure 5-2, "Plant Plant Staffing and Augmentation Requirements."
Requirements.
In Reference 2, ENO received a request for additional information (RAI) concerning the LAR, and ENO responded to the RAI in Reference 3. ENO received a second RAI in Reference 4, and responded to the second RAI in Reference 5. ENO received a third RAI in Reference 6, and responded to the third RAI in Reference 7. The third RAI response proposed adding a 30-minute RP technician responder to perform in-plant protective actions.
Following submission of the third RAI response, ENO and the NRC held a conference call on August 19, 2014 to discuss the third RAI response. As a result of the conference call, ENO is hereby submitting a supplement to the LAR that modifies the proposed ERO staffing and augmentation requirements for RP technicians that were provided in the LAR (Reference 1) and in the response to the third RAI (Reference 7) 7).. With these modifications, the proposed changes to RP technician staffing and augmentation requirements are as follows:
- A second RP technician is added to the on-shift staff.
- control,,
For offsite surveys, onsite (out-of-plant) surveys, in-plant surveys, access control RP coverage, personnel monitoring, and dosimetry, three RP technicians will respond within 60 minutes and three RP technicians will respond within 90 minutes.
- For onsite field monitoring, one RP technician will report within 60 minutes.
- For offsite field monitoring, one RP technician and one driver will report within 60 minutes, and one RP technician and one driver will report within 90 minutes.
minutes.
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The on-shift RP technicians and the RP technician augmented responders would be qualified to perform assigned tasks, which include offsite surveys, onsite (out-of-plant) surveys, in plant surveys, access control duties, RP coverage for workers, personnel monitoring, dosimetry, and field monitoring.
These modifications to augmentation requirements for RP technicians concern the two Radiological Accident Assessment and Support of Operational major functional areas (1) "Radiological Assessment and (2) Protective Actions (In-Plant)"
Accident Assessment" (In-Plant) in SEP Figure 5-2. The proposed changes concerning augmentation response times for ERO positions in the other major functional areas remain unchanged from the LAR in Reference 1. Therefore, information provided in the previous submittals concerning the remaining functional areas positions is not affected by the proposed changes in this supplement. of this supplement contains an updated SEP Figure 5-2 which depicts the proposed changes concerning staffing and augmentation requirements for RP technicians. This figure supersedes the figures previously provided in Attachment 3 of Affachment 2 of the third RAI response.
the LAR and in Attachment Information provided in this supplement concerning the ERO staffing and augmentation requirements for RP technicians supersedes RP technician information provided in the Reference 1 1 LAR, the Reference 5 response to the second RAI, and in the Reference 7 response to the third RAI.
- 2. Detailed Description of Changes The PNP SEP currently requires the following with regard to the RP technicians:
- Major Functional Area: Radiological Accident Assessment and Support of 30-minute augmented RP technician Operational Accident Assessment - Two 3D-minute responders and two 60-minute augmented RP technician responders are available to perform offsite surveys.
- Maior Functional Area: Radiological Accident Assessment and Support of Major 30-minute augmented RP technician Operational Accident Assessment - One 3D-minute responder and one 60-minute augmented RP technician responder are available to perform onsite (out-of-plant) surveys.
- Maior Functional Area: Radiological Accident Assessment and Support of Major 30-minute Operational Accident Assessment - One on-shift RP technician, one 3D-minute augmented RP technician responder, and one 60-minute augmented RP technician responder are available to perform in-plant surveys.
- Major - 30-minute augmented Maior Functional Area: Protective Actions (In-Plant) - Two 3D-minute RP technician responders and two 60-minute augmented RP technician responders are available to perform access control, RP coverage, personnel monitoring, and dosimetry major tasks.
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The total numbers of RP technicians for these functions in the current SEP are one on-shift RP technician, six 30-minute RP technician responders, and six 60-minute RP technician responders.
As described inin Attachment 2, the proposed changes to the SEP 2, the SEP would would result in:
- Major Functional Area: Radiation Protection - Two on-shift Maior on-shift RP technicians, three gO-minute RP technician 60-minute RP technician responders, and three 90-minute responders are available to perform offsite surveys, onsite (out-of-plant) surveys, in-plant surveys, access control, RP coverage, personnel monitoring, and dosimetry major tasks.
- Major Functional Area: Field Monitoring Teams - One RP technician reporting within 60 minutes is available to perform onsite field monitoring. This RP technician would assess environmental radiation/contamination and provide input to the individual providing senior radiation protection expertise. This RP technician would also provide RP coverage for the field monitoring team. A driver is not needed to support onsite field monitoring.
- Major Functional Area: Field Monitoring Teams - One RP technician and one driver reporting within 60 minutes, and one RP technician and one driver reporting 90 minutes, are available to perform offsite field monitoring. These RP within gO technicians would perform environmental radiation/contamination assessments and radioactive plume tracking. The RP technicians would communicate and coordinate with applicable ERO supervision, and would also be responsible for the radiation protection of the field team.
The total numbers of RP technicians for these functions in the proposed changes to the SEP are two on-shift RP technicians, five 60-minute RP technician 90-minute RP technician responders.
responders, and four gO-minute As shown in the revised SEP Figure 5-2 in Attachment 2, major tasks performed by RP Radiological Accident Assessment and Support technicians that were previously in the "Radiological Protective Actions (In-Plant)"
Assessment and "Protective of Operational Accident Assessment" (In-Plant) Major Functional Radiation Protection,"
Areas are combined in a new Major Functional Area titled "Radiation Protection, and a (FMTs), is added for the Field Monitoring Teams (FMTs),"
new Major Functional Area, titled "Field onsite and offsite field monitoring major tasks.
90-minute RP technician responders The on-shift RP technicians and the 60-minute and gO-minute would be qualified to perform assigned tasks, which include offsite surveys, onsite workers, (out-of-plant) surveys, in-plant surveys, access control duties, RP coverage for workers, personnel monitoring, dosimetry, and field monitoring.
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- 3. Technical Analysis The technical bases for the proposed changes involving the RP technicians are provided below for each task.
Offsite Radiological Surveys - The change in response time for offsite radiological survey responders is acceptable because there is no expected need to perform these surveys within at least the first 60 minutes of the event due to the use of installed post-accident effluent radiation monitors. In the unlikely event that an offsite survey is needed, the two on-shift RP technicians would be available to perform the offsite survey. Offsite surveys are not expected to be needed during the initial stages of an event because expected release pathways are monitored release points. During at least the first 60 minutes of an event, in-plant radiation monitoring instrumentation would be used because radiological release instrument data is readily obtained. Onsite surveys or installed post-accident effluent radiation monitors can provide rapid indication of a release of radioactive materials and can be used for offsite dose assessment calculation purposes.
Onsite (Out-of-Plant) and In-Plant Surveys - The need for onsite out-of-plant or in-plant surveys before the augmented responders arrive is unlikely. During the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. In-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency, thereby reducing the need to send RP personnel into the plant to obtain radiological data, particularly when assessing initial radiological conditions in the early stages of an event. The radiological monitoring instrumentation ensures that both RP and ERO members are kept informed of current and changing radiological conditions. In plant radiological instrumentation provides a continuous radiological status of the rooms monitored and provides local and remote alarming capability. Thirty-four continuous monitoring points within the plant are selected to provide indication and warning where radioactivity may be present using area radiation monitors. All of these monitors have an upper range of at least 10 1 77 mrem/hr, which provides sufficient range to provide indication of escalating radioactive environments for severe accident conditions. In the unlikely event that an onsite or in plant survey is needed, the on-shift RP technicians are available to perform onsite and in-plant surveys before the augmented responders arrive.
Access Control and Personnel Monitoring - At the time of the original SEP in 1982, radiological access control was a labor intensive task. Dedicated RP technicians were required to check dose margins, training qualifications, and to ensure workers had read and understood their radiation work permit. Worker access control is now automated because radiation protection work processes have been computerized. Radiation work permit access control and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on their radiation work permit and to self-issue electronic dosimeters. Both systems have been used by plant workers for several years.
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Worker dose margins and training qualifications are also automatically verified when the workers dose margin is radiation work permit access control system is used. If a worker's inadequate or training is expired, the workers worker's access would be precluded and the access control system would not allow issuance of an electronic dosimeter. During the log-in process, workers acknowledge their electronic dosimeter alarm setpoints and that they have read and understand their radiation work permit. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and will alarm at preset dose and dose rate alarms. Should personnel receive an alarm on dose or dose rate, they are required to exit the area immediately for additional instructions and follow-up. Worker use of electronic dosimeters facilitates more efficient use of RP technicians to provide RP coverage while preserving the ALARA concept.
Access control is maintained because the worker must obtain an electronic dosimeter and enter a radiation work permit number into the access control computer system prior to being allowed access into the Controlled Access Area (CAA). No setup is required for the radiation work permit access control computers, which allows RP technicians to be used for more critical tasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit any CAA. No RP involvement is necessary for this contamination monitoring activity because workers are trained to perform this task without supervision or oversight.
In addition, PNP provides a specific radiation work permit with emergency dose and dose rate limits for entry into areas under accident conditions. Dedicated electronic alarming dosimeters set to the emergency radiation work permit limits are provided in the immediate Control Room area and at the radiological access control point. The established dose and dose rate limits for this radiation work permit are set for levels significantly higher than those expected for work performed under normal operating conditions. These values represent turn back limits where, if encountered, work is stopped, the area is exited, and additional instructions and follow-up with the Shift Manager and Radiation Protection is required, protecting worker safety. This radiation work permit is continuously available on the automated radiological access control system and does not require action by an on-shift RP Technician to set up or initiate for use.
The proposed changes in RP technician response times are supported by current access control and personnel monitoring processes and equipment.
RP Coverage - The need for RP coverage for workers in the plant before the RP technician augmented responders arrive would be limited. In the early stages of a postulated emergency event, the major site response activities are concentrated on determining the cause of the event, identifying the status of plant equipment, and following emergency operating procedures to place the plant in a safe condition. Only after plant status is understood and the plant is in a stable condition would operator attention be focused on corrective maintenance that may be needed to restore plant capabilities.
RP coverage would only be needed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a task. The of 99 5 of
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 materials.
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, multiple emergency teams can be covered by the on-shift RP technicians. In addition to the coverage provided by the RP staff, Chemistry personnel are trained in the use of some portable radiation survey instruments so that certain on-shift functions can be performed without the assistance of RP technicians. If RP coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate setpoints) and because of the installed ARMs (which alarm locally and remotely at preset dose rates) located throughout the plant. Should personnel receive an alarm on dose or dose rate, they are required to exit the area immediately for additional instructions and follow-up.
Dosimetry - When the SEP was originally issued, dosimetry issuance was a manual training,,
process requiring RP technicians to zero and issue dosimeters, verify worker training and verify and track radiation dose margins. As addressed in the Access Control/Personnel Monitoring Section above, access control computers are now used for issue of electronic dosimetry with alarming capability. Battery powered electronic dosimeters are available as a backup. Worker self-issuance of electronic dosimeters has eliminated the need for RP technicians to physically issue dosimetry with the exception of any tasks that require specialized dosimetry and/or special body placement of the dosimetry. These types of tasks are not expected in the initial stages of an event, but during the recovery phase.
The changes concerning the augmented RP technician responders are supported by reductions in RP technician workload due to improvements in RP processes and equipment, and would not impact the ability of the on shift staff to mitigate an emergency event.
Field Monitoring Teams Onsite and offsite field monitoring teams are added to SEP Figure 5-2.
Onsite field monitoring is performed by one RP technician reporting within 60 minutes.
This RP technician would assess environmental radiation/contamination and provide input to the individual providing senior radiation protection expertise. This RP technician would also provide RP coverage for the field monitoring team.
Offsite field monitoring is performed by one RP technician and one driver reporting within 60 minutes, and one RP technician and one driver reporting within 90 minutes. These RP technicians would perform environmental radiation/contamination assessments and radioactive plume tracking. The RP technicians would communicate and coordinate with applicable ERO supervision, and would also be responsible for the radiation protection of the field team.
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During the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. In-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency, thereby reducing the need to send RP personnel to obtain onsite radiological data, particularly when assessing initial radiological conditions in the early stages of an event. The radiological monitoring instrumentation ensures that both RP and ERO members are kept informed of current and changing radiological conditions. In the unlikely event that onsite field monitoring is needed, the on-shift RP technicians would be available to perform onsite field monitoring before the augmented responders arrive.
Offsite field monitoring is not expected to be needed during the initial stages of an event.
During at least the first 60 minutes of an event, in-plant radiation monitoring instrumentation would be used because radiological release instrument data is readily obtained. Onsite field monitoring or installed post accident effluent radiation monitors can provide rapid indication of a release of radioactive materials and can be used for offsite dose assessment calculation purposes. In the unlikely event that offsite field monitoring is needed within the first 60 minutes, the two on-shift RP technicians would be available to perform the offsite field monitoring before the augmented responders arrive.
- 4. Update to No Significant Hazards Consideration This supplement to the LAR concerning tasks performed by RP technicians impacts the no significant hazards consideration that was provided in the LAR (Reference 1).
Therefore, an updated no significant hazards consideration which reflects the RP technician changes is provided below that supersedes in its entirety the no significant hazards consideration in the LAR.
Updated No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (ENO) is proposing a license amendment to the Palisades Nuclear Plant (PNP) Site Emergency Plan (SEP). The proposed amendment would add a second radiation protection (RP) technician to the on-shift staff, would increase certain Emergency Response Organization (ERO) positions with 30-minute staff augmentation response times to 60-minute response times, and would add field monitoring teams as 60-minute and 90-minute augmented responders.
ENO has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment,"
"Issuance amendment, as discussed below:
11.. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
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The proposed changes do not affect previously analyzed event probabilities or any parameters associated with plant operations. The changes affect the site response to radiological emergencies under the PNP SEP. The effect of the proposed changes on the ability of the ERO to respond adequately to radiological emergencies has been evaluated, and the proposed changes would not significantly affect the ability of the site to perform the required SEP tasks.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes have no effect on the plant design or on the normal operation of the plant, and do not affect how systems and components are operated under emergency conditions. The proposed changes affect the site response to radiological emergencies under the PNP SEP. The changes do not significantly affect the ability of the site to respond to radiological emergencies and perform required ERO functions, and do not affect the plant operating procedures which are performed by plant staff during all plant conditions.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed change does not affect plant design, method of plant operation, or any protective boundaries. 10 CFR 50.47 (b) and 10 CFR 50 Appendix E E establish emergency planning standards and requirements for adequate staffing, satisfactory performance of key functional areas and critical tasks, and timely augmentation of the response capability. Since the PNP SEP was originally developed, there have been improvements in the technology used to support the SEP functions and the capabilities of onsite personnel. The proposed changes do Thus, not significantly affect the ability of the ERO to perform required SEP tasks. Thus, the proposed change does not adversely affect the ability to meet the emergency planning standards as described in 10 CFR 50.47 (b) and the requirements in 10 CFR 50 Appendix E.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, END ENO concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, no significant hazards consideration" accordingly, a finding of "no consideration is justified.
justified.
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- 5. References
- 1. 2013-044, License Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-044, Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated June 25, 2013 (ADAMS Accession No. ML113176A405).
ML 31 76A405).
- 2. NRC email to ENO, MF2321 PNP Request for Additional Information (RAI) for License Amendment Request to Revise ERO Staff Augmentation Response Times, dated July 23, 2013 (ADAMS Accession No. ML ML13205A163).
13205A 163).
- 3. ENO letter to NRC, PNP 2013-060, Response to Request for forAdditional Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated August 7, 2013 (ADAMS Accession No. No.
ML 3220A008).
- 4. NRC email to ENO, Request for Additional Information - Palisades - Proposed Revision to Palisades Site Emergency Plan (SEP) to increase the staff Augmentation response time for certain Emergency Response Organization (ERO) positions from 30 to 60 minutes - MF2321, dated December 16,
- 16, 2013 (ADAMS Accession No. MLML13353A042).
13353A042).
- 5. ENO letter to NRC, PNP 2014-003, Response to December 16, 2013 Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated February 13, 13, 2014 (ADAMS Accession No. ML ML14044A059).
14044A059).
- 6. NRC email to ENO, Request for Additional Information - Palisades - LAR to Revise Emergency Response Response Organization Staff Augmentation Response Times - -
1, 2014 (ADAMS Accession No. ML MF2321, dated May 1,2014 ML14121A282).
14121A282).
- 7. ENO letter to NRC, PNP 2014-051, Response to May 1, 2014 Request for forAdditional Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated July 16, 2014.
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ATTACHMENT 22 Proposed Revision to Palisades Nuclear Plant Site Emergency Plan Pages FIGURE 5-2 PLANT STAFFING AND AUGMENTATION REQUIREMENTS POSITION TITLE ON STAFF AUGMENTATION MAJOR FUNCTIONAL AREA MAJOR TASKS CAPABILITY AND OR EXPERTISE SHIFT RESPONSE TIME 60Mm 60 Min 90Mm 90 Min Plant Operations and Shift Engineer/Shift 11 --
Assessment of Operational Technical Advisor (SRO) --
Aspects Shift Manager (SRO) 11 --
Control Room Supervisor 11 -- --
(SRO)
Control Room Operators 2 -- --
Nuclear Plant Operators 6 -- --
I Emergency Director Shift Manager 11*
- Notification/ state, Notify licensee, state, 11 3 --
Communication local, and federal personnel and maintain communication - - ------ - - - - - - - - --- --
functions..
May be provided by shift personnel assigned other functions 11 of 4
FIGURE FIGURE 5-2 5-2 PLANT PLANT STAFFING STAFFING AND AND AUGMENTATION AUGMENTATION REQUIREMENTS REQUIREMENTS POSITION TITLE ON STAFF AUGMENTATION MAJOR FUNCTIONAL AREA MAJOR TASKS CAPABILITY AND OR EXPERTISE SHIFT RESPONSE TIME 60Mm 60 Min 90Mm 90 Min Radiological Accident Emergency Operations Senior Manager --
-- 1 1 --
Assessment and Support Facility (EOF) Director of Operational Accident Offsite Dose Assessment Senior Radiation Protection 1 1*
- 1 1 -
Assessment (RP) Expertise Chemistry/Radiochemistry Chem Technicians 1 1 1 1 --
Radiation Protection Radiation Protection Tasks: RP Technicians 2 3 3
- a. Offsite Surveys
- b. Onsite (Out-of-Plant)
Surveys
- c. In-Plant Surveys
- d. Access Control
- e. RP Coverage
- f. Personnel Monitoring
- g. Dosimetry Plant System Technical Support Core/Thermal Hydraulics CorelThermal 1*
1* 1 1 --
Engineering, Repair, Electrical 1 1 --
and Corrective Actions Mechanical --
-- 1 1 --
Repair and Corrective Mechanical Maintenance 1 1*
- 1 1 --
Actions Radwaste Operator -- 1 1 --
Electrical Maintenance 1 1*
- 2 --
Instrument and Control (I&C) Technician --
-- 1 1 --
- May be provided by shift personnel assigned other functions.
20f4 2 of 4
FIGURE 5-2 PLANT STAFFING AND AUGMENTATION REQUIREMENTS POSITION TITLE ON STAFF AUGMENTATION MAJOR FUNCTIONAL AREA MAJOR TASKS CAPABILITY AND OR EXPERTISE SHIFT RESPONSE TIME Mm 60 Min Mm 90 Min Field Monitoring Teams (FMTs) Onsite FMT - Radiation RP Technician --
-- 1 --
monitor to assess environmental radiation/contamination and provide input to Senior Radiation Protection Expertise.
Also provide RP coverage for FMT.
Offsite FMT - Perform RP Technicians --
-- 1 1 environmental radiation/contamination assessments and radioactive plume tracking. Communicate and coordinate with applicable ERO supervision. Responsible for the radiation protection of the FMT.
Transportation Drivers -- 1 1 Fire Fighting -- -- Fire Brigade Local Support per Technical Specifications
-- I 30f4 3 of 4
FIGURE FIGURE 5-2 5-2 PLANT STAFFING AND PLANT STAFFING AUGMENTATION REQUIREMENTS AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION POSITION TITLE ON CAPABILITY AND MAJOR FUNCTIONAL AREA MAJOR TASKS RESPONSE TIME OR EXPERTISE SHIFT Mm 60 Min I Mm 90 Min Rescue Operations --
-- 2*
2* Local Support and First-Aid Site Access Control Security, fire fighting Security Personnel All per and Personnel communications, personnel Security accountability Plan TOTAL 15 20 5 NOTES: 1. Staff augmentation personnel are required to respond as quickly as possible, within the required response time.
- 2. The Shift Manager may call out additional designated ERO members, or the full ERO complement, at any time in an emergency 2.
classification.
event regardless of classification.
3.
- 3. Even when they are not on duty, staff augmentation personnel are to respond to an emergency call out when they are fit for duty and otherwise available for timely response.
- May be by shift personnel assigned other functions.
be provided by 40f4 4 of 4