ML19192A097

License Amendment Request for Emergency Plan, July 11, 2019

ML19192A097
Person / Time
Site:	Palo Verde
Issue date:	07/11/2019
From:	Arizona Public Service Co
To:	Division of Operating Reactor Licensing
Lingam S, 301-415-1564
References
Download: ML19192A097 (8)

Text

Palo VerdeLicense Amendment Request for Emergency PlanJuly 11, 2019 Change based on the following:NRC June 12, 2018 correspondence to NEI, Alternative Guidance for Licensee Emergency Response Organizations (ML18022A352

)Technical Basis for Section II.B, Table B

-1 of NUREG-0654, Revision 2 (ML16117A427)Exelon Midwest License Amendment Request

(M L18053A159) and approved Safety Evaluation (ML19036A586) for changes to their Emergency Response OrganizationPalo Verde LAR 2 3Critical Elements of License Amendment RequestNo change to current augmentation timeframes and process Augment at Alert for all facilities and ERO positionsUse of an "All Call" and duty roster process for staffing60 minutes during normal working hours and 120 minutes off hoursSupplemented Rev. 2 NUREG 0654 on shift ERO to support maintaining 120 minute off hours augmentationIncrease RP technicians to support onsite or offsite monitoring as neededRP Supervision/Dose Assessment on

-shiftEnsure that key ERO functions can be maintained for timeframe prior to augmented resources arrival Palo Verde LAR 4Critical Elements of License Amendment Request (cont'd)Remove on-shift Chemistry and Maintenance personnelIncrease number of augmented ERO consistent with guidance in Rev. 2Remove non

-minimum staff positions from the emergency plan (maintain in procedures

)State of Arizona has reviewed and supports this amendment requestState and federal agencies will be invited to a once every drill cycle minimum staff drillPalo Verde LAR 5Additional resources to support the key ERO functions remain in place on

-shift: Additional Radiation Protection support for onsite and offsite field monitoring is available if needed The number of auxiliary operators on site (12, 4 per unit) allows for additional efforts to support operations and maintenance critical activities during the 120 minute augmentation timeDose Assessment and Radiation Protection leadership available on shiftOffsite communications to State and Local government and the NRC Palo Verde LAR 6Additional resources to support the key ERO functions remain in place on shift (cont'd

): Engineering Support in the form of the unaffected unit Shift Technical AdvisorSecurity Leadership to support the callout process Augmented Command and Control assistance to the affected Unit Shift Manager in the form of two on

-shift Shift Managers/Emergency Coordinators from the unaffected UnitsShift Managers, Control Room Supervisors and Shift Technical Advisors are trained to the Emergency Coordinator position qualificationPalo Verde LAR Palo Verde LARSchedule for LAR submittal 3rd Quarter 2019NRC review and Issuance of Safety Evaluation1 yearScheduled ImplementationSix Months following approval 7

Discussion/Questions