ML20259A206

Defueled Safety Analysis Report, Chapter 5, Conduct of Facility Activities

ML20259A206
Person / Time
Site:	Indian Point
Issue date:	09/14/2020
From:	Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20259A199	List: ML20259A200 ML20259A201 ML20259A202 ML20259A203 ML20259A204 ML20259A205 ML20259A206 ML20259A207 ML20259A208 ML20259A209 ML20259A210 ML20259A211 ML20259A212 ML20259A213 ML20259A214 ML20259A215 ML20259A216 ML20259A217 NL-20-066, Engineering Report IP-RPT-11-00032, Revision 5, Licensing Report on the Inter-Unit Transfer of Spent Nuclear Fuel at the Indian Point Energy Center
References
NL-20-066
Download: ML20259A206 (4)

Text

IP2 DEFUELED SAFETY ANALYSIS REPORT CHAPTER 5 CONDUCT OF FACILITY ACTIVITIES 5.1 Organization and Responsibility Operation and maintenance of the Indian Point Unit 2 facility is the responsibility of the Entergy Nuclear organization. The management organization and functional responsibilities as they relate to the operation and maintenance of the Indian Point facility are discussed in DSAR Section 1.6.3 and in the IPEC Quality Assurance Program Manual (QAPM).

5.1.1 Facility Staff The corporate officer with direct responsibility for the facility shall have corporate responsible for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in maintaining and providing technical support to the facility to ensure safe management of nuclear fuel.

The Plant Manager is responsible for overall facility operation and has control over those onsite activities necessary for storage and maintenance of nuclear fuel. The Plant Manager shall delegate in writing the succession to this responsibility during his absence.

The facility organization, duty shift composition, control room occupancy, and other requirements for site personnel are in accordance with the Technical Specifications.

A fire brigade is maintained on the site at all times. The organization, operation and training of the fire brigade is discussed in the document under separate cover entitled, "IPEC Fire Protection Program Plan."

5.1.2 Facility Staff Qualifications Each member of the facility staff meets or exceeds the minimum qualifications of ANSI / ANS-3.1-1978 for comparable positions with exceptions specified in the IPEC QAPM.

Certified Fuel Handlers shall be trained in accordance with the NRC approved training and retraining program for Certified Fuel Handlers.

5.2 Training A retraining and replacement training program for the facility staff shall be maintained.

An NRC approved training and retraining program for Certified Fuel Handlers shall be maintained.

The training program for the fire brigade is described in the document under separate cover entitled, "IPEC Fire Protection Program Plan."

An emergency plan training program is maintained to cover licensee and non-licensee individuals or groups assigned to the various functional areas of emergency activity.

Radiation protection training is given to personnel requiring unescorted access to controlled areas of the facility.

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IP2 DEFUELED SAFETY ANALYSIS REPORT Training requirements for the security force are set forth in the Indian Point, Physical Security, Training and Qualification, Safeguard Contingency Plan, and Independent Spent Fuel Storage Installation Program.

5.3 Written Procedures Written procedures and administrative policies are established, implemented, and maintained in accordance with the IPEC QAPM, the IP2 Renewed Facility License, and the Appendices A through C Technical Specifications.

5.3.1 Emergency Plan Implementing Procedures Emergency plan implementing procedures (EPIPs) provide instructions and outline responsibilities of on-site and off-site personnel for the IPEC facility in the event of an emergency at IP2.

5.4 Records Records concerning facility activities, including historical operations, are maintained in the form of logbooks, charts, and other such internal reports as may be needed to document pertinent facility conditions. The principal logs to be maintained by the shift manager and other site personnel, as applicable. These logs include descriptions of the facility conditions that exist at the time, descriptions of significant operational efforts accomplished during the shift, and such facility events or circumstances as are deemed pertinent to maintain proper continuity of knowledge and understanding of such matters as responsibility in those areas is passed on from shift to shift.

A record of radiation safety conditions, internal and environmental, is maintained in the form of appropriate log entries, and continuous recording chart information in those functional systems and areas provided with radiation survey instruments. In addition, Radiation Work Permit survey information provides the necessary record of radiation exposure conditions prior to job commencement. Actual personnel radiation exposure information is maintained.

Records of controlled radiation releases to the environment are maintained by site personnel, and all necessary information describing specific radioactivity concentrations, total volumes released, along with any dilution requirements, are entered on the Radioactive Waste Release Permit prepared for each release.

All abnormal occurrences that occur during the course of facility activities are recorded in the shift manager's logbook and, where appropriate, in the logbooks maintained by site personnel.

Facility modification records (e.g., procedures, drawings, specifications) are maintained on file.

Detailed records of total uranium, U-235, Pu-239, and Pu-241 for all fuel in use or in storage are maintained. Records of fuel transfers are maintained via proper execution of NRC forms. Specific locations for all fuel assemblies in the reactor core or in the fuel storage pools are maintained on appropriate core or fuel storage pool arrangement drawings.

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IP2 DEFUELED SAFETY ANALYSIS REPORT Record maintenance and retention is in accordance with the requirements of the IPEC QAPM. Records are maintained on paper, microfilm/aperture cards, or optical disk storage media. Procedures for maintenance of optical disk records comply with the guidance of NRC Generic Letter 88-18 Plant Record Storage on Optical Disks.

5.5 Review and Audit of Facility Activities Matters such as design changes to the facility which require a license amendment, changes to facility procedures, or changes to the Technical Specifications, are conducted in accordance with the requirements of 10 CFR 50 and the IPEC QAPM. To assist in this function, Entergy has chartered two committees specifically for the review of safety-related items. These committees (i.e., the On-Site Safety Review Committee and the Safety Review Committee) function in accordance with the requirements of the IPEC QAPM.

A continuing review of facility activities is performed by the facility staff and at the executive level.

5.5.1 On-Site Safety Review Committee (OSRC)

The On-Site Safety Review Committee functions to advise on all matters related to nuclear safety in accordance with the requirements of the IPEC QAPM.

5.5.2 Safety Review Committee (SRC)

The Safety Review Committee functions to provide independent review and audit of designated activities and facility activities in accordance with the requirements of the IPEC QAPM.

5.5.3 Qualification of Inspection, Examination, Testing, and Audit Personnel Entergys commitments and exceptions related to the qualification of inspection, examination, testing, and audit personnel are described in the IPEC QAPM.

5.6 Plant Security The program for ensuring the physical security of the Indian Point Unit 2 station has been reviewed by the NRC and found acceptable. The fully implemented security plan provides the protection needed to meet the general performance requirements of 10 CFR 73.55(a) and the objectives of the specific requirements of 10 CFR 73.55, paragraphs (b) through (k), without impairing the ability to operate the facility safely. The approved facility security program, titled "Indian Point, Physical Security, Training and Qualification, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, is addressed in the 10 CFR 50 facility license. The approved security plan documents and the NRC Security Plan Evaluation Report have been withheld from public disclosure pursuant to 10 CFR 2.390(d).

Access to Indian Point Units 1, 2 and 3 areas for all persons is controlled under approved procedures administered by the Station Security Department.

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IP2 DEFUELED SAFETY ANALYSIS REPORT 5.7 Emergency Plan In accordance with 10 CFR 50.54(q), the Indian Point Energy Center (IPEC) Emergency Plan (Plan) outlines the basis for response actions that would be implemented in an emergency. Detailed Plan implementing procedures are maintained separately and used to guide those responsible for implementing emergency actions. This plan documents the methods by which IPECs Emergency Preparedness Program meets the criteria set forth in 10 CFR 50.47(b) and Appendix E.

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