View source for BVY 17-039, Response to Request for Additional Information Regarding the License Amendment Request to Change the Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-Only Configuration

{{Adams
| number = ML17325B020
| issue date = 11/16/2017
| title = Response to Request for Additional Information Regarding the License Amendment Request to Change the Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-Only Configuration
| author name = 
| author affiliation = Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/NMSS, NRC/NRR
| docket = 05000271, 07200059
| license number = DPR-028
| contact person = 
| case reference number = BVY 17-039, EPID L-2017-EPR-0001
| document type = Response to Request for Additional Information (RAI)
| page count = 17
| project = EPID:L-2017-EPR-0001
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:BVY 17-039 Docket Nos. 50-271 and 72-59 Attachment 1 Vermont Yankee Nuclear Power Station Response to Request for Additional Information

BVY 17-039 / Attachment 2 / Page 1 of 5 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE AMENDMENT REQUEST TO CHANGE THE EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME TO REFLECT AN ISFSI-ONLY CONFIGURATION FOR VERMONT YANKEE NUCLEAR POWER STATION Request for Additional Information:
RAI-VY-1
* Section 1.0, "Introduction," of the NRG-approved PDEP states, in part:
The analysis of the potential radiological impact of design basis accidents in a permanently defueled condition indicates that any releases beyond the Site Boundary are below the Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposure levels, as detailed in the EPA's "Protective Action Guide and Planning Guidance for Radiological incidents," Draft for Interim Use and Public Comment dated March 2013 (PAG Manual). Exposure levels, which warrant pre-planned response measures, are limited to onsite areas. For this reason, radiological emergency planning is focused onsite.
Section 1.0, "Introduction," of the proposed VY ISFSI Emergency Plan states, in part:
As provided in the Holtec FSAR [Final Safety Analysis Report}, the analyses of the potential radiological impacts of postulated off-normal, natural phenomena, and accident events involving the ISFSI indicate that any releases would result in a dose to the public below the radiation limits established in 10 CFR 72.106(b).
Exposure levels,' which warrant pre-planned response measures are limited to the ISFSI and immediate vicinity, and for this reason, radiological emergency planning is focused on this area.
Provide technical basis for removal of reference to EPA PAGs in the ISFSI EP with respect to design basis accidents. Also consider updating the reference to the recently updated EPA PAG Manual (EPA-400/R-17/001, January 2017).

===Response===
Section 2.0 of the LAR states: "There continues to be no need for offsite emergency response plans at VY because no postulated design basis accident (OBA) or reasonably conceivable beyond design basis event can result in a radiological release that exceeds Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the Exclusion Area Boundary (EAB or "Site Boundary'J, as described in EPA's "Protective Action Guides and Planning Guidance for Radiological Incidents, dated January 2017 (EPA PAG Manual)
(Reference 5)."
In response to the above request, the third paragraph of Section 1.0 of the VY Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan (IEP) will be revised to refer to the EPA PAGs, with respect to DBAs. Attachment 2 of this response provides the revised IEP pages with the proposed changes shown in strikethrough and underline format.

BVY 17-039 / Attachment 2 / Page 2 of 5 RAI-VY-2    Section 11.1, "Emergency Notification," of the NRG-approved PDEP states, in part:
The format and contents of the initial message between the plant and State/Commonwealth authorities are specified in notification procedures and have been established with the review and agreement of responsible state authorities.
The Department of Public Health of Vermont, New Hampshire and Massachusetts may request the following information from VY:
: 1. Date and time of the incident;
: 2. Emergency classification;
: 3. Status of the facility;
: 4. Whether a release has occurred, is occurring, or is anticipated to occur;
: 5. Actual or projected dose rates at the Site boundary; Section 9.2, "Emergency Messages," of the proposed VY ISFSI Emergency Plan states, in part:
The format and content of the initial message between VY and Vermont, New Hampshire, and Massachusetts are specified in EPIPs and have been established with the review and agreement of responsible state authorities. The initial notification contains the following information, as available:
* Identification of the facility
* Identification of the message sender
* Date and Time of the emergency declaration
* Emergency classification, including EAL Provide basis for not including any information related to a potential radiological release (per PDEP items 4 and 5, above) as part of the initial notification, or reinsert into proposed VY ISFSI Emergency Plan.

===Response===
Based upon the above question, section 9.2 of the VY IEP will be updated (per PDEP items 4 and 5, above) to describe the content of messages, including a description of radiological conditions. Attachment 2 of this response provides the revised IEP pages with the proposed changes shown in strikethrough and underline format.
RAI-VY-3    Section 7.4, "Mobile UHF Radio System," of the NRG-approved PDEP states, in part:
Security also has the capability to contact the primary local law enforcement agency patrol vehicle(s), as defined in the VY Physical Security Plan, that are located in close proximity to the plant via radio.
Table 10-1, "Communications Systems" of the proposed VY ISFSI Emergency Plan identifies portable radios as a communication system in use.

BVY 17-039 / Attachment 2 / Page 3 of 5 Clarify whether these portable radios have this same capability to contact the primary local law enforcement agency patrol vehicle(s), as defined in the VY Physical Security Plan.

===Response===
The portable radios identified in Table 10-1 will have the same capability to contact the primary local law enforcement agency patrol vehicles that may be in close proximity to VY, as defined in the VY Physical Security Plan.
RAI-VY-4     NUREG-0654, Section II, Evaluation Criterion N.2.b states, "Fire drills shall be conducted in accordance with the plant (nuclear facility) technical specifications."
Section 12.1.4, "Fire Drills," of the NRG-approved PDEP states, in part:
To test and evaluate the response and training of the plant's fire brigade, fire drills are conducted in accordance with the Vermont Yankee Fire Protection Program.
However, a provision for fire drills is not included in Section 18.0, "Exercises and Drills," of the proposed VY ISFSI Emergency Plan.
Clarify whether the Vermont Yankee Fire Protection Program will continue to include fire drills on some routine frequency and, as applicable, provide basis for removal or reinsert into the proposed VY ISFSI Emergency Plan:

===Response===
VY will continue to conduct fire drills in accordance with the VY Fire Protection Program.
Section 18.2 of the VY IEP is revised to clarify performance of fire drills as shown in the new section 18.2.5. Attachment 2 of this response provides the revised IEP pages with the proposed changes shown in strikethrough and underline format.
RAI-VY-5     NUREG-0654, Section II, Evaluation Criterion N.1.a states, "The [exercise] scenario should be varied from year to year such that all major elements of the plans and preparedness organizations are tested.
Section 18.0, "Exercises and Drills," of the proposed VY ISFSI Emergency Plan does not provide a statement indicating whether scenarios will vary from year to year and what elements of the plan are tested.
Provide justification for removal of this statement from the proposed VY ISFSI Emergency Plan, or reinsert as appropriate.

===Response===
Section 18.1 of the VY IEP will be revised to clarify that VY will continue to vary exercise scenarios, to the extent practicable, such that all major elements of the plans and preparedness organizations are tested. Attachment 2 of this response provides the revised IEP pages with the proposed changes shown in strikethrough and underline format.

BVY 17-039 / Attachment 2 / Page 4 of 5 RAI-VY-6     NUREG-0654, Section II, Eval.uation Criterion P.3 states, "Each licensee shall designate an Emergency Planning Coordinator with responsibility for the development and updating of emergency plans and coordination of these plans with other response organizations."
However, Section 20.1.2, "Emergency Preparedness Responsibilities," of the proposed VY ISFSI Emergency Plan states, in part:
A VY ISFSI position is designated the responsibility for maintaining an adequate knowledge of emergency preparedness regulations, emergency planning techniques, and the latest applications: of emergency equipment and supplies.
Clarify, by title, which VY ISFSI position is in charge of maintaining the emergency plan and reviews, and coordination of these plans with other response organizations.

===Response===
Section 20.1 of the VY IEP will be revised to clarify that the VY ISFSI senior management position is responsible for maintaining an adequate knowledge of emergency planning regulations, emergency planning techniques, and the latest applications of emergency equipment and supplies. Attachment 2 of this response provides the revised IEP pages with the proposed changes shown in strikethrough and underline format.
RAI-VY-7     EAL E-HU1.1, "Damage to a loaded cask CONFINEMENT BOUNDARY," of the VY proposed ISFSI Emergency Plan states:
Two times the ISFSI Technical Specification allowable levels equate to:
* 14.80 mR/hr on the top of the overpack or
* 16.62 mR/hr on the side of the overpack, excluding inlet and outlet ducts This is not consistent with the NRG-approved Permanently Defueled EAL Scheme.
: a. Provide the basis for the change to these values; and
: b. Verify whether these values (as stated in one hundredths of a unit) can be accurately read by VY radiation Instruments. If required, revise values appropriate to ensure they can be accurately read on radiation instruments.

===Response===
: a. Based upon the request above, and consistent with the guidance provided in NEI 99-01, Rev. 6, VY will utilize an on-contact radiation reading greater than 2 times the site-specific cask specific technical specification allowable radiation levels as the threshold for declaring Emergency Action Level (EAL) E-HU1 .1. Because the VY ISFSI contains casks loaded under Amendments 2 and 10 of the Holtec International HI-STORM 100 Cask System Certificate of Compliance (CoC) No. 72-1014, the proposed EAL will utilize the allowable levels of Amendment 2 as these are comparable to Amendment 1O and would be the first to

BVY 17-039 / Attachment 2 / Page 5 of 5 be reached in the case of a confinement boundary failure issue. Two times the Technical Specification allowable values (Technical Specification 5. 7.4) equate to:
* 40 mR/hr (gamma+ neutron) on the top of the overpack
* 220 mR/hr (gamma + neutron) on the side of the overpack, excluding inlet and outlet ducts Attachment 3 of this response provides the revised pages of the EAL Technical Bases Document and Attachment 4 provides the revised page from the Comparison Matrix of NEI 99-01 to the proposed VY Emergency Classification System and the ISFSI EALs with the proposed changes shown in strikethrough and underline format. It is noted that, under the provisions of 10 CFR 72.2112, applying the changes authorized by an amended CoC to a cask loaded under an earlier amended CoC may result in a corresponding change to the applicable site-specific cask specific technical specification allowable radiation levels, which would be subject to the change process at 10 CFR 50. 54( q)(3).
: b. VY instrumentation have the capability to read the EAL values described in Part a of this response.

BVY 17-039 Docket Nos. 50-271 and 72-59 Attachment 2 Vermont Yankee Nuclear Power Station Revised pages of ISFSI Emergency Plan}}