ML20163A037

The Independent Spent Fuel Storage Installation - Issuance of Amendment Nos. 213, 213, and 213 to Revise Emergency Plan Staff Augmentation Times

ML20163A037
Person / Time
Site:	Palo Verde
Issue date:	07/31/2020
From:	Siva Lingam Plant Licensing Branch IV
To:	Lacal M Arizona Public Service Co
Lingam S, 301-415-1564
References
EPID L-2019-LLA-0222
Download: ML20163A037 (29)

Text

July 31, 2020 Mrs. Maria L. Lacal Executive Vice President/

Chief Nuclear Officer Arizona Public Service Company P.O. Box 52034, Mail Station 7605 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 AND THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION - ISSUANCE OF AMENDMENT NOS. 213, 213, AND 213 TO REVISE EMERGENCY PLAN STAFF AUGMENTATION TIMES (EPID L-2019-LLA-0222)

Dear Mrs. Lacal:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment Nos. 213, 213, and 213 to Renewed Facility Operating License Nos. NPF-41, NPF-51, and NPF-74 for the Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2, and 3, respectively, and the general license for the Independent Spent Fuel Storage Installation.

The amendments revise the Palo Verde Emergency Plan in response to your application dated October 18, 2019, as supplemented by letter dated March 13, 2020.

Specifically, the amendments change the emergency response organization staffing composition for certain emergency response organization positions.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA Jennifer L. Dixon-Herrity for/

Siva P. Lingam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, STN 50-530, and 72-44

Enclosures:

1. Amendment No. 213 to NPF-41

2. Amendment No. 213 to NPF-51

3. Amendment No. 213 to NPF-74

4. Safety Evaluation cc: Listserv

ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-528 PALO VERDE NUCLEAR GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 213 License No. NPF-41

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated October 18, 2019, as supplemented by letter dated March 13, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 213, Renewed Facility Operating License No. NPF-41 is hereby amended to authorize changes to the Palo Verde Nuclear Generating Station Emergency Plan, as set forth in APSs application dated October 18, 2019, as supplemented by letter dated March 13, 2020, and evaluated in the NRC staffs safety evaluation for this amendment.

3.

This license amendment is effective as of the date of issuance and shall be implemented on or before June 30, 2021.

FOR THE NUCLEAR REGULATORY COMMISSION Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: July 31, 2020 Mirela Gavrilas Digitally signed by Mirela Gavrilas Date: 2020.07.31 10:12:50 -04'00'

ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-529 PALO VERDE NUCLEAR GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 213 License No. NPF-51

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated October 18, 2019, as supplemented by letter dated March 13, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 213, Renewed Facility Operating License No. NPF-51 is hereby amended to authorize changes to the Palo Verde Nuclear Generating Station Emergency Plan, as set forth in APSs application dated October 18, 2019, as supplemented by letter dated March 13, 2020, and evaluated in the NRC staffs safety evaluation for this amendment.

3.

This license amendment is effective as of the date of issuance and shall be implemented on or before June 30, 2021.

FOR THE NUCLEAR REGULATORY COMMISSION Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: July 31, 2020 Mirela Gavrilas Digitally signed by Mirela Gavrilas Date: 2020.07.31 10:13:27 -04'00'

ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-530 PALO VERDE NUCLEAR GENERATING STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 213 License No. NPF-74

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated October 18, 2019, as supplemented by letter dated March 13, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 213, Renewed Facility Operating License No. NPF-74 is hereby amended to authorize changes to the Palo Verde Nuclear Generating Station Emergency Plan, as set forth in APSs application dated October 18, 2019, as supplemented by letter dated March 13, 2020, and evaluated in the NRC staffs safety evaluation for this amendment.

3.

This license amendment is effective as of the date of issuance and shall be implemented on or before June 30, 2021.

FOR THE NUCLEAR REGULATORY COMMISSION Ho K. Nieh, Director Office of Nuclear Reactor Regulation Date of Issuance: July 31, 2020 Mirela Gavrilas Digitally signed by Mirela Gavrilas Date: 2020.07.31 10:28:17 -04'00'

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 213, 213, AND 213 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51, AND NPF-74 FOR ARIZONA PUBLIC SERVICE COMPANY, ET AL.

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 GENERAL LICENSE FOR INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NOS. STN 50-528, STN 50-529, STN 50-530, AND 72-44

1.0 INTRODUCTION

By application dated October 18, 2019 (Reference 1), as supplemented by letter dated March 13, 2020 (Reference 2), Arizona Public Service Company (APS, the licensee) requested changes to the Emergency Plan pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(q), Emergency plans, for the Palo Verde Nuclear Generating Station (Palo Verde, PVNGS), Units 1, 2, and 3, and Independent Spent Fuel Storage Installation (ISFSI). The proposed changes would revise the Palo Verde Emergency Plan to change the emergency response organization (ERO) staffing composition for certain ERO positions. The Palo Verde Emergency Plan refers to Palo Verde Units 1, 2, and 3, and the Palo Verde ISFSI.

The licensees proposed revisions to the Palo Verde Emergency Plan include:

Reduction of two on-shift electrical maintenance technician positions; Reduction of one on-shift maintenance technician position; Reduction of two on-shift radiation protection (RP) technician positions; Removal of an on-shift chemistry technician from the Palo Verde Emergency Plan; and Relocation of certain non-minimum staffing positions from the Palo Verde Emergency Plan to the applicable Palo Verde Emergency Plan Implementing Procedures (EPIPs).

The supplemental letter dated March 13, 2020, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC, the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on November 19, 2019 (84 FR 63897).

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance on which the NRC staff based its review are provided below.

2.1 Regulatory Requirements The planning standards in 10 CFR 50.47(b) establish the requirements that the onsite and offsite emergency response plans must meet for the NRC staff to make a finding that there is reasonable assurance that the licensee can, and will, take adequate protective measures in the event of a radiological emergency. Specifically, on-shift and augmented ERO staffing is addressed under 10 CFR 50.47(b)(2), which states:

On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV, Content of Emergency Plans, Part A, Organization, states, in part:

The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization and the means for notification of such individuals in the event of an emergency.

2.2 Regulatory Guidance Regulatory Guide 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors, dated October 1981 (Reference 3), provides guidance on methods acceptable to the NRC staff for implementing specific parts of the NRCs regulations, which in this case are 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. Regulatory Guide 1.101 endorses Revision 1 to NUREG-0654/FEMA-REP-1 (hereafter referred to as NUREG-0654), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980 (Reference 4), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47(b). These criteria provide a basis for NRC licensees, and State and local governments to develop acceptable radiological emergency plans and to improve emergency preparedness.

NUREG-0654,Section II, Planning Standards and Evaluation Criteria, Evaluation Criteria II.B.1 and II.B.5 address the planning standard of 10 CFR 50.47(b)(2).

Evaluation Criterion II.B.1 states:

Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement.

Evaluation Criterion II.B.5 states, in part:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.

Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (Reference 5), provides examples of the scope and detail of information that should be provided in license amendment requests related to ERO staffing and augmentation to facilitate the NRC staffs review.

In a letter to the Nuclear Energy Institute dated June 12, 2018 (Reference 6), the NRC staff provided alternative guidance to Evaluation Criterion II.B.5 in NUREG-0654, Revision 1, for minimum ERO on-shift and augmentation staffing. The letter stated, in part:

The NRC has revised Section II.B, Table B-1 of NUREG-0654, based in part on comments received from the public on the draft Revision 2 of NUREG-0654, located at www.regulations.gov under Docket ID FEMA-2012-0026. The revised ERO staffing guidance has been finalized, and the NRC will include it when the entire NUREG-0654, Revision 2, is ready for issuance. Until then, the NRC staff is making available on an interim basis the ERO on-shift and augmentation staffing plan (attached). Regardless of whether a licensee chooses to use the guidance contained in Revision 1 of NUREG-0654, the attached, or an alternative approach, licensees are still required to adhere to 10 CFR 50.54(q) when revising their ERO staffing plans.

Hereafter, Table B-1, Emergency Response Organization (ERO) Staffing and Augmentation Plan, which is an attachment to the letter dated June 12, 2018, will be referred to as Interim Table B-1 in this safety evaluation.

Subsequent to the submission of this license amendment request (LAR), NUREG-0654, Revision 2 (Reference 7), was published. There were no changes inconsistent with those identified in Interim Table B-1. For consistency with the LAR, this safety evaluation will use Interim Table B-1 when referencing Table B-1 of NUREG-0654.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of the proposed changes to the Palo Verde Emergency Plan as described in the LAR dated October 18, 2019, as supplemented by letter dated March 13, 2020. The NRC staffs technical evaluation of the proposed changes is detailed below.

3.1 Enhancements An evaluation based upon the major functional areas of the Palo Verde ERO was performed, and many of the proposed changes are supported by enhancements to equipment (technology) and by procedural, training, and process improvements, as described below.

3.1.1 Plant Monitoring The Palo Verde Plant Monitoring System provides for real time monitoring and trending of plant parameters. The benefits of the Plant Monitoring System include:

Monitoring, alarming, and logging functions; Information needed to assess the status of the plant safety parameters based on measurement of key plant variables; A concise display of critical plant variables to aid in rapid and reliable determination of the safety status of the plant; and Real time plant data available through graphical displays.

3.1.2 Dose Assessment Dose assessment at Palo Verde was originally performed via a disk operating system-based computer program that required manual entry of plant parameters to perform a dose assessment. The current dose assessment capability uses a Windows-based program that minimizes the number of menu navigation commands and allows plant data to be directly imported into the software program. Thus, enhancements in dose assessment software have reduced the time required to perform dose assessments.

3.1.3 Automated Call-Out Systems Since initial approval of the Palo Verde Emergency Plan, APS has streamlined the ERO activation process. Previously, Palo Verde used individual calls to fill ERO positions. Currently, Palo Verde uses a web-based or phone-based system to rapidly notify ERO members. The system includes a primary activation system as well as backup capability to ensure uninterrupted operation.

3.1.4 Procedural Improvements The licensee provides that the emergency action levels (EALs) for Palo Verde now incorporate guidance that has simplified the emergency classification process. This includes the use of an overview matrix of EAL initiating conditions and threshold values, which streamlines the process of evaluating EALs against plant conditions. Additionally, emergency operating procedures have been vastly improved through internal operating experience and industry initiatives.

Emergency operating procedures now use a symptom-based approach that demands less assessment and interpretation of plant conditions by the operating crews. Overall, the improvements made to procedures greatly reduce the operators reliance on the ERO during the initial phases of any event.

3.1.5 Training The licensee provides that training is used to strategically drive and sustain improved performance at Palo Verde. Training is administered through the application of the Systematic Approach to Training to ensure that all training is conducted to the industry-accepted standards required to achieve and maintain accreditation by the National Academy of Nuclear Training.

The proficiency of the control room team is evaluated in the areas of critical task performance, prioritization of activities, communications, accident mitigation, event classification, teamwork and communications.

3.2 Major Functional Areas In the LAR dated October 18, 2019, APS provided a justification for the proposed Palo Verde Emergency Plan changes that included a detailed review of each major functional area described in Interim Table B-1.

The current Palo Verde Emergency Plan describes the ERO as consisting of personnel staffing in the following emergency response facilities:

Control Room/Satellite Technical Support Center; Technical Support Center (TSC);

Operations Support Center (OSC);

Emergency Operations Facility (EOF); and Joint Information Center (JIC).

APS proposes to continue activating the TSC, OSC, EOF, and JIC within 60 minutes of the declaration of an Alert or higher classification level during normal working hours and within 120 minutes of the declaration of an Alert or higher classification level during off hours (60/120 minutes). Although activation of the EOF would not be required until a Site Area Emergency or higher classification level is declared per the guidance in Interim Table B-1, the proposed changes to the Palo Verde Emergency Plan require the TSC, OSC, EOF, and JIC to activate at an Alert or higher classification level.

The NRC staffs review of the proposed changes to the Palo Verde Emergency Plan, based on each major functional area, is described below.

3.2.1 Command and Control The purpose of the command and control function is to: (1) provide overall ERO command and control, until relieved; (2) approve EAL and/or protective action recommendation (PAR) classifications, until relieved; and (3) authorize personnel dose extensions, until relieved.

The proposed staffing for command and control is consistent with Interim Table B-1 with two differences. Specifically, the EOF emergency director and the TSC emergency coordinator positions will be staffed within 60/120 minutes of the declaration of an Alert or higher classification level, while Interim Table B-1 provides for TSC staffing within 60 minutes of the declaration of an Alert or higher classification level and EOF staffing within 60 minutes of the declaration of a Site Area Emergency or General Emergency classification level.

APS is not proposing to change the Palo Verde command and control staffing and will continue to have on-shift personnel that will allow an unaffected unit shift manager to relieve the affected

unit shift manager of the emergency coordinator function as needed. The NRC staff considers staffing the emergency operations director and emergency coordinator as an enhancement because it will ensure that the TSC and EOF EROs will be mobilized and available should an Alert classification escalate to a Site Area Emergency or General Emergency.

Also, to align with Interim Table B-1, APS proposed to change its current emergency direction and control functional area to command and control.

The NRC staff reviewed the licensees proposed changes to the command and control function and found them acceptable based on the information discussed above. The licensee provided adequate justification for proposed changes, which differed from Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding effective and timely command and control of licensee emergency response.

3.2.2 Communications The purpose of the communications function is to communicate EAL and PAR classifications to offsite response organizations (OROs) and the NRC, until relieved. The licensee provided its analysis of the communications function in Section 3.2.2, EP [Emergency Preparedness]

Function: Communications, of the enclosure to the LAR, License Amendment Request -

Changes to Emergency Plan Staffing Requirements.

Interim Table B-1 recommends that following the declaration of an Alert or higher classification level, the TSC be staffed with two communicators within 60 minutes and an additional communicator, as needed, within 90 minutes. In addition, Interim Table B-1 recommends the staffing of one communicator in the EOF within 60 minutes of declaring a Site Area Emergency or General Emergency classification level. Palo Verde will maintain the emergency notification system communicator position in the TSC and the State/local communicator position in the EOF, with both positions being staffed within 60/120 minutes of the declaration of an Alert or higher classification level.

APS currently uses two on-shift ERO members to perform the NRC and State/local communication tasks. APS currently provides one NRC emergency notification system communicator at the TSC and a State/local communicator within 60/120 minutes of an Alert or greater classification level. Additionally, APS provides that on-shift communicators will have no collateral duties assigned under the Palo Verde Emergency Plan once communication duties are assumed. APS is not proposing changes to the Palo Verde Emergency Plan for the communications function. APS is proposing to not use a note from Interim Table B 1 that would allow on-shift communicators to be assigned collateral duties.

A statement is proposed to be added to the staffing tables that additional communicators will be staffed as needed. This ensures that, if required, additional communicators can be augmented to support communications between APS and OROs, including the NRC.

The NRC staff reviewed the licensees proposed changes to the communications function and found them acceptable based on the information discussed above. The licensee provided adequate justification for the proposed changes, which differed from Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to the meet planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding maintaining timely and effective communications with the NRC and designated OROs.

3.2.3 Radiation Protection The purpose of the RP function is to: (1) provide qualified RP coverage for responders accessing potentially unknown radiological environments during emergency conditions; (2) provide in-plant surveys; and (3) control dosimetry and radiologically controlled area access.

APS provided its analysis of the RP Function in Section 3.2.3, EP Function: Radiation Protection, of the enclosure to the LAR.

This function is currently staffed by four on-shift RP technicians and two on-shift RP support personnel, who are not required to be qualified as RP technicians. The licensee will maintain four RP technicians on-shift to perform the RP tasks and remove the two RP support positions.

APS provides, and the NRC staff agrees, that three RP technicians can provide access control and job coverage, with a fourth RP technician who will perform the field monitoring function.

Consistent with Interim Table B-1, APS proposed to only list qualified RP personnel on-shift for this function without providing a specific breakdown of the assigned tasks. Therefore, removing both of the two RP support personnel, who were not required to be qualified as RP technicians, and a note clarifying that the in-plant protective actions may be performed by persons assigned to other functions, does not impact the timing or capability to perform the RP function.

In addition to on-shift RP technicians, Interim Table B-1 identifies three RP technicians staffing the OSC within 60 minutes with an additional three RP technicians staffing the OSC within 90 minutes of the declaration of an Alert or higher classification level. Currently, the Palo Verde Emergency Plan designates six minimum staff RP technicians, as required, to augment and support the emergency plan major tasks of in-plant surveys and in-plant protective actions within 60/120 minutes. APS currently provides that six RP technicians will respond within 60/120 minutes of an Alert or higher classification level. APS is proposing to continue to provide six RP technicians within 60/120 minutes of an Alert or higher classification level. The licensee stated that technological advances in protection coverage for responders, in-plant surveys, dosimetry, and radiologically controlled area access, as described in Section 3.2.3 of the enclosure to the LAR, support the proposed augmentation times. Based on APS continuing to provide six augmenting RP technicians within 60/120 minutes of an Alert or higher classification level, the NRC staff finds that the proposed augmentation to the minimum staff for the RP function is acceptable.

APS also proposed to remove chemistry personnel from the on-shift and minimum staffing list for the RP function based on a determination that the chemistry major task is not required per Palo Verde Emergency Plan procedures prior to augmentation. A chemistry/radiation chemistry function is not included in Interim Table B-1. APS further stated that the need for immediate reactor coolant sampling has been reduced due to the variety of available plant indications of fuel damage available at Palo Verde. Specifically, early indications of fuel damage can be identified through containment radiation monitors, core exit thermocouples, or effluent radiation monitors, all of which are available in the control room. Based on this, the NRC staff finds that the removal of the chemistry personnel from the on-shift and minimum staffing list for the RP function is acceptable.

The NRC staff reviewed the licensees proposed changes to the RP function and found them acceptable based on the information discussed above. The licensee provided adequate justification for proposed changes which differed from the Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of RP functions.

3.2.4 Supervision of Radiation Protection Staff and Site Radiation Protection The purpose of the supervision of RP staff and site RP function is to: (1) evaluate and assess plant and offsite radiological data in the development of onsite protective actions and offsite PARs, until relieved; (2) recommend onsite protective actions and offsite PARs to the applicable decision-maker, until relieved; (3) direct all RP activities, including radiological field assessment team (RFAT) direction, until relieved; and (4) provide relevant information to applicable communicators who are communicating offsite PARs to OROs, until relieved. APS provided its analysis of the supervision of RP function in Section 3.2.4, EP Function: Supervision of Radiation Protection Staff and Site Radiation Protection, of the enclosure to the LAR.

Interim Table B-1 identifies an operations shift manager to perform the supervision of RP function on-shift, until relieved. The current Palo Verde Emergency Plan provides that an RP monitor (now proposed to be called the RP monitor/RP group leader), who is a senior RP technician, will report to the affected unit control room to provide supervision of the RP technicians on-shift. As such, the on-shift RP monitor/RP group leader relieves the operations shift manager of RP-related supervisory functions. APS is not proposing a change to this functional area.

Interim Table B-1 recommends that the supervision of RP function be augmented by a site RP coordinator in the TSC within 60 minutes of the declaration of an Alert or higher classification level and by an RP manager in the EOF within 60 minutes of the declaration of a Site Area Emergency or General Emergency classification level. Currently, the APS staffs both a TSC RP coordinator and an EOF radiological assessment coordinator within 60/120 minutes of the declaration of an Alert or higher classification level. APS is not proposing a change to this function.

The NRC staff reviewed the licensees proposed changes to the supervision of RP function and found them acceptable based on the information discussed above. The licensee provided adequate justification for proposed changes which differed from Interim Table B-1. Specifically, APS will provide on-shift RP supervision capability, which is an enhancement to the guidance provided in Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the effective supervision of the RP function.

3.2.5 Dose Assessments/Projections The purpose of the dose assessments/projections function is to perform dose assessments and projections and to provide input to the applicable PAR decision-maker, until relieved. APS provided its analysis of the dose assessments/projections function in Section 3.2.5, EP Function: Dose Assessments/Projections, of the enclosure to the LAR.

Interim Table B-1 identifies a dose assessment/projection staff member as performing this function on-shift and clarifies that: Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time. Currently, Palo Verde uses the on-shift RP monitor, now proposed to be called the RP monitor/RP group leader, to perform this function prior to augmentation.

Interim Table B-1 recommends one dose assessment/projection position to be staffed at the TSC within 60 minutes of the declaration of an Alert or higher classification level and another dose assessment/projection position to be staffed at the EOF within 60 minutes of the declaration of a Site Area Emergency or General Emergency classification level. Currently, APS staffs one dose assessment health physicist at the EOF within 60/120 minutes of the declaration of an Alert or higher classification level. APS is not proposing a change to this function. APS proposed to include the dose assessment health physicist position on the proposed Table 1, Minimum Shift Staffing for Emergencies, of the Palo Verde Emergency Plan. The current Palo Verde Emergency Plan included the dose assessment as an EOF function on Figure 4, Emergency Operations Facility Organization, and did not specifically include dose assessment on the current Table 1 of the Palo Verde Emergency Plan.

The EOF dose assessment health physicist will perform radiological dose projections and provide input to the radiological assessment coordinator. Since the EOF is mobilized simultaneously with the TSC, responsibility for dose assessment is transferred directly from the control room to the EOF. APS stated, and the NRC staff agrees, that staffing of the dose assessment/projection position in the TSC is redundant and, therefore, not required.

The NRC staff reviewed the licensees proposed dose assessments/projections function and found it acceptable based on the information discussed above. With the proposed changes, the licensees on-shift Table 1will be consistent with Interim Table B-1. The licensee provided adequate justification for the proposed changes, which differed from Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to the meet planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding the timely and effective performance of radiological dose assessments and projections.

3.2.6 Emergency Classifications The purpose of the emergency classifications function is to evaluate plant conditions and recommend emergency classifications, until relieved. APS provided its analysis of the emergency classifications function in Section 3.2.6, EP Function: Emergency Classifications, of the enclosure to the LAR.

Interim Table B-1 recommends an emergency classification advisor to perform this function on-shift and clarifies that: Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any

given time. Currently, the Palo Verde Emergency Plan does not specify a separate emergency classifications function for the on-shift or augmenting minimum staff. The licensee proposed to assign this function to a pre-existing on-shift staff member (i.e., shift technical advisor (STA)) as a collateral duty.

Interim Table B-1 recommends that the on-shift emergency classification advisor be augmented by a second emergency classification advisor in the TSC within 60 minutes of the declaration of an Alert or higher classification level. APS proposed to assign the TSC emergency classification advisor function to the TSC operations manager, with the shift emergency coordinator continuing to have the non-delegable command and control responsibility for emergency classification decisions. As such, the STA and TSC operations manager positions will advise the shift emergency coordinator.

The NRC staff reviewed the licensees proposed changes to the emergency classifications function and found them acceptable based on the information discussed above. With the proposed changes, the licensees emergency plan will provide an individual to perform the emergency classifications function.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding the timely and accurate classification of emergency events.

3.2.7 Engineering The purpose of the engineering function is to provide engineering coverage related to core/thermal-hydraulics, electrical/instrumentation and control (I&C), and mechanical systems and equipment, until relieved. APS provided its analysis of the engineering function in Section 3.2.7, EP Function: Engineering, of the enclosure to the LAR.

Interim Table B-1 recommends a core/thermal-hydraulics engineer to evaluate reactor conditions for the on-shift engineering function and clarifies that: Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time. Currently, Palo Verde has the STA satisfy the on-shift responsibilities for the plant system engineering, repair, and corrective actions function, which is re-categorized as the engineering function in Interim Table B-1. APS proposed to revise the Palo Verde Emergency Plan to identify the engineering function as a collateral duty satisfied by the STA on-shift. The NRC staff finds this proposed change acceptable because it is consistent with Interim Table B-1.

Interim Table B-1 recommends that the TSC minimum staff for the engineering function consists of the following:

One core/thermal hydraulics engineer to support the evaluation of reactor conditions; One mechanical engineer for coverage of ERO-related mechanical equipment; and One electrical/I&C engineer for coverage of ERO-related electrical and I&C equipment.

Currently, the Palo Verde Emergency Plan identifies the following positions as the minimum staff for the engineering function:

One reactor analyst; One mechanical engineer; One electrical/I&C engineer; and One EOF engineering director.

APS proposed to retain the reactor analyst, the mechanical engineer, and the electrical/I&C engineer as the minimum staff for the engineering function, which will be staffed within 60/120 minutes from the declaration of an Alert or higher classification level. APS provides that STAs are senior reactor operator-licensed or senior reactor operator-certified (in accordance with the Palo Verde STA accredited training program) and degreed engineers that attend license operator continuing training. APS further states that the STAs are trained and qualified to provide mechanical and electrical support for troubleshooting using existing plant procedures utilizing their senior reactor operator level of knowledge.

Consistent with the guidance provided in Interim Table B-1, APS proposed to remove the EOF engineering director from Table 1, Minimum Staffing for Emergencies. APS proposed to maintain the EOF engineering director position actions in an applicable EPIP. The NRC staff finds this change acceptable because the EOF engineering director will still respond as an augmentation position and the proposed Table 1 staffing in the Palo Verde Emergency Plan is consistent with Interim Table B-1.

The NRC staff reviewed the licensees proposed changes to the engineering function and found them acceptable based on the information discussed above. With the proposed changes, the licensees emergency plan will be consistent with Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding the engineering function.

3.2.8 Security APS provided its analysis of the security function in Section 3.2.8, EP Function: Security, of the enclosure to the LAR.

Interim Table B-1 recommends the on-shift security function to be provided by security staffing per the site-specific security plan. For the on-shift security function, the Palo Verde Emergency Plan is currently consistent with Interim Table B-1; therefore, APS is not proposing any changes.

Interim Table B-1 recommends that the on-shift security staffing should be augmented by a security liaison in the TSC within 60 minutes of the declaration of an Alert or higher classification level to coordinate security-related activities and information with the emergency coordinator.

APS proposed to maintain an on-shift security director who supports the emergency coordinator in the control room and in the TSC once activated. This will ensure timely and effective coordination between the security force and the ERO, particularly for events where offsite

resources are necessary, as well as for security-related events and site personnel accountability.

APS did not propose changes to on-shift or augmented minimum staff related to the security function. As such, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding the security function.

3.2.9 Repair Team Activities APS provided its analysis of the repair team activities function in Section 3.2.9, EP Function:

Repair Team Activities, of the enclosure to the LAR.

Interim Table B-1 recommends that the following maintenance personnel should respond to the OSC to support repair team activities:

One electrician and one mechanic within 60 minutes of the declaration of an Alert or higher classification level to provide support for emergency core cooling system equipment, event mitigation, and equipment repair and One I&C technician within 90 minutes of the declaration of an Alert or higher classification level to provide assistance with logic manipulation, support for event mitigation and equipment repair, and support of digital I&C, if applicable.

The current Palo Verde Emergency Plan identifies two mechanical technicians, three electrical technicians, and one I&C technician as on-shift positions. In the proposed Palo Verde Emergency Plan, these positions will be identified with the term maintenance (e.g., electrical maintenance technician). APS proposed to remove one mechanical technician and two electrical technicians from on-shift staffing. As proposed, APS will provide on-shift capabilities that are consistent with the Interim Table B-1 guidance.

The current Palo Verde Emergency Plan does not provide augmenting maintenance technicians. APS proposed that one mechanical maintenance technician, one electrical maintenance technician, and one I&C maintenance technician will respond within 60/120 minutes from the declaration of an Alert or higher classification level. APS proposed that additional maintenance technicians would be available and called in as needed.

APS provided that Palo Verde utilizes on-shift non-licensed operators to perform severe accident management guideline, extensive damage management guideline, and diverse and flexible mitigation capability procedures. The tasks associated with these procedures are contained within accredited training programs for non-licensed operators. As such, Palo Verde has the capability to restore or functionally recover critical safety functions by performing severe accident management guideline, extensive damage management guideline, or flexible mitigation capability procedures as well as progressing on repair activities associated with the restoration of critical safety functions until augmentation within 60/120 minutes of an Alert or higher classification level.

The NRC staff reviewed the licensees proposed changes to the repair team activities function and found them acceptable based on the information discussed above. With the proposed changes, the licensees emergency plan will be consistent with Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding repair team activities.

3.2.10 Supervision of Repair Team Activities APS provided its analysis of the supervision of repair team activities function in Section 3.2.10, EP Function: Supervision of Repair Team Activities, of the enclosure to the LAR.

Interim Table B-1 indicates that an on-shift repair team supervisor is not needed to support the emergency plan. Currently, the Palo Verde Emergency Plan has the shift manager/emergency coordinator responsible for on-shift response until augmentation is complete. Additionally, an unaffected unit shift manager is available to assist in the control of repair activities, if needed.

As such, APS is not proposing any changes related to an on-shift repair team supervisor.

Interim Table B-1 also recommends a lead OSC supervisor to staff the OSC within 60 minutes with a mechanical supervisor, RP supervisor, electrical supervisor, and I&C supervisor (who may be combined with the electrical supervisor) to staff the OSC within 90 minutes from the declaration of an Alert or higher classification level.

Currently, the Palo Verde Emergency Plan identifies the OSC manager and TSC maintenance manager as supervisory positions for repair and corrective actions. APS proposed to re-categorize the TSC maintenance manager position as full-augmented staff under an appropriate EPIP, while adding one repair team coordinator for electrical/I&C maintenance, one repair team coordinator for mechanical maintenance, one RP monitor/RP group leader, and one OSC manager as OSC minimum staff positions to perform the supervision of repair team activities function. These positions will be staffed within 60/120 minutes from the declaration of an Alert or higher classification level.

APS stated that its lead technicians under its maintenance and RP program are qualified, experienced craft technicians who successfully demonstrate the day-to-day leadership of the technician work force and act as leads on back shifts. Duties and responsibilities of lead technicians include training and development of other employees in performing preventive maintenance and routine equipment service activities. Basic qualifications for a lead technician include demonstrated reliability and responsibility and the ability to make quick and effective technical decisions, as well as demonstrated situational leadership, and environmental and safety stewardship. The licensee stated, and the NRC staff agrees, that the experience and qualification of the lead technicians for maintenance and RP would satisfy the requirements and the needs of the OSC for the supervision of repair team activities function.

The NRC staff reviewed the licensees proposed changes to the supervision of repair team activities function and found them acceptable based on the information discussed above. With the proposed changes, the licensees emergency plan will be consistent with Interim Table B-1.

The licensee provided adequate justification for proposed changes which differed from Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding the supervision of repair team activities.

3.2.11 Field Monitoring Teams APS provided its analysis of the RFAT in Section 3.2.11, EP Function: Field Monitoring Teams, of the enclosure to the LAR.

Interim Table B-1 recommends one onsite RFAT and two offsite RFATs as minimum staff.

Each RFAT would consist of a driver and one qualified individual (i.e., a field monitor) to assess the area for radiation and contamination. The field monitors for the offsite RFATs would also provide radioactive plume tracking. The onsite RFAT and one offsite RFAT are recommended to be staffed within 60 minutes and the second offsite RFAT is recommended to be staffed within 90 minutes from the declaration of an Alert or higher classification level.

Currently, Palo Verde has one RP technician and one RFAT driver designated as minimum staff to perform onsite/offsite surveys. Palo Verde currently provides that an additional RP technician and RFAT driver will respond within 60/120 minutes from the declaration of an Alert or higher classification level. APS is not proposing a change to the field monitoring staffing. The licensees proposed changes to Table 1 of the Palo Verde Emergency Plan combine the RP and field monitoring functions. Table 1 indicates that appropriate staffing is designated to perform both the radiation protection and field monitoring functions.

The NRC staff reviewed the licensees proposed changes and found them acceptable based on the information discussed above. With the proposed changes, the licensees emergency plan will be consistent with Interim Table B-1. The licensee provided adequate justification for proposed changes which differed from Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding field monitoring.

3.2.12 Media Information The purpose of the media information function is to coordinate and manage media information related to the event. APS provided its analysis of the media information function in Section 3.2.12, EP Function: Media Information, of the enclosure to the LAR.

The APS and Palo Verde communication departments currently support the Palo Verde facility at all times. The Palo Verde Communication Department coordinates with APS management and respective emergency response facilities to respond to media inquiries and issue press releases as appropriate.

Interim Table B-1 recommends that JIC staff address media inquiries within 60 minutes of the declaration of an Alert or higher classification level but notes that this function does not need to be performed at the TSC or OSC. The Interim Table B-1 further recommends additional staff to perform JIC-related tasks within 60 minutes of the declaration of a Site Area Emergency or General Emergency classification level. For the JIC, Interim Table B-1 notes: Emergency response facility activation timing is not the concern; it is whether the facility staff is performing the stated function(s) within the time specified. Interim Table B-1 does not specify an on-shift capability and does not identify specific staff positions for the minimum staff.

Currently, the Palo Verde Emergency Plan identifies the following positions as minimum staff positions that report to the JIC following the declaration of an Alert or higher classification level:

Palo Verde Spokesperson; JIC Manager; Emergency Response Facility Communicator-JIC; Research/Writing Coordinator; Spokesperson Coordinator; Distribution Services Coordinator; Video/Photo Coordinator; and Media Monitor/Rumor Control Coordinator.

However, no specific response time is currently designated for these positions. The licensee proposed to change the Palo Verde Emergency Plan to provide a JIC Manager position that will be established within 60/120 minutes of an Alert or higher classification level. The APS and Palo Verde communication departments will continue to respond and address events until the JIC is activated.

APS provides that a JIC manager will staff the JIC to maintain command and control of the facility and conduct periodic briefings with the news media. The JIC manager will also coordinate with the State, Local, and Federal agencies to maintain factual consistency of information conveyed.

Based on the information above, the NRC staff determined that the JIC Manager and the JIC staff for handling media inquiries are sufficient to manage and coordinate media information related to the event. The NRC staff finds that the 60/120 minute response time for the JIC Manager and the JIC staff tor handling media inquiries is acceptable because the APS and Palo Verde communication departments will maintain the ability to respond to media inquiries at all times.

The NRC staff reviewed the licensees proposed changes to the media information function and found them acceptable based on the information discussed above. With the proposed changes, the licensees emergency plans will be consistent with Interim Table B-1. The licensee provided adequate justification for the proposed changes, which differed from Interim Table B-1.

Based on the above evaluation, the NRC staff has determined that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A regarding media information.

3.2.13 Information Technology The purpose of the information technology (IT) function is to provide support for computer-based equipment if relied upon to perform emergency plan functions. APS provided its analysis of the IT function in Section 3.2.13, EP Function: Information Technology, of the enclosure to the LAR.

Interim Table B-1 indicates that IT staff is only required to be described in the emergency plan if critical digital assets are identified per 10 CFR 73.54[, Protection of digital computer and communication systems and networks]. As such, Interim Table B-1 recommends an IT lead staff the TSC within 90 minutes of the declaration of an Alert or higher classification level and

that another IT lead staff the EOF/JIC within 60 minutes of the declaration of a Site Area Emergency or General Emergency classification level. Consistent with Interim Table B-1, APS stated that there are no on-shift staff assigned to the IT function. APSs IT Department maintains a helpdesk available at all times to assist users with IT-related issues.

Currently, APS maintains an information services manager at the EOF as an augmented minimum staff position. APS stated that a minimum staff position is not needed at either the TSC or EOF based on acceptable performance of digital equipment during drills and exercises and built-in redundancy of communication systems and digital emergency plan assets. The licensee stated that the EOF and TSC contain multiple computers and programs in the facility, which are used during training and are periodically tested. If issues are identified during testing, they are promptly addressed. In addition, many computer issues can be addressed remotely by the IT helpdesk. If additional help is needed at the TSC or EOF, an IT specialist at the help desk will be available to support resolution of the issue. If additional IT support is needed, an IT specialist will be promptly dispatched to address the issue.

Although there is a difference between the proposed staffing of the IT function and Interim Table B-1, the NRC staff has determined that the licensee will provide for an effective IT system, through multiple IT resources. Based on the above evaluation, the NRC staff concludes that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for the IT function.

3.2.14 Resource Allocation and Administration The Palo Verde Emergency Plan includes a resource allocation and administration function.

APS provided that the current full-augmented staffing includes an EOF administrative/logistics coordinator and administrative support positions depending on the type and extent of the emergency. APS provided that no resource allocation and administration tasks are required to accomplish any NUREG-0654 identified functions. As such, the proposed removal of the position of administrative/logistics coordinator and administrative support staff from the proposed Palo Verde Emergency Plan is acceptable.

Based on the above evaluation, the NRC staff concludes that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for the resource allocation and administration function.

3.2.15 First Aid and Rescue Operations Note viii to Interim Table B-1 indicates, The number of staff from operations, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents.

APS stated in Section 2.1.3, On-Shift ERO Revision Summary, of the enclosure to the LAR that the designated number of fire brigade personnel will be removed from the Palo Verde Emergency Plan and that the firefighting function will be controlled per the site fire protection plan. The NRC staff has determined that the proposed change is acceptable because the firefighting function will continue to be controlled under the NRC-approved fire protection program.

Based on the above evaluation, the NRC staff concludes that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A for the First Aid and Rescue Operations function.

3.3 Full Augmentation Staffing Full-augmentation positions are not described in either Table B-1 of NUREG-0654, Revision 1, or Interim Table B-1. Interim Table B-1 only addresses the required minimum staffing to perform the designated major functional areas, as compared to other staff not critical to the effective implementation of the emergency plan. Note iii to Interim Table B-1, as stated below, describes the distinction between ERO minimum staffing and ERO members, who serve in a supporting capacity.

The minimum ERO staffing plan is that which is required to effectively implement the site-specific emergency plan (i.e., the emergency plan cannot be effectively implemented without this staff). The emergency plan should only describe the minimum ERO staffing plan, while supporting implementing procedures can describe any additional staff response desired by the licensee, as this additional staff is not critical to effective emergency plan implementation. The augmentation times listed are intended to provide a model for applicants and licensees to consider in the development of their site-specific emergency plan.

APS stated in Section 3.3, Full-Augmented Staff Assessment, of the enclosure to the LAR that the Palo Verde Emergency Plan will describe the minimum ERO staff needed to implement the emergency plan (i.e., if any position or function is not staffed, then the emergency plan cannot be effectively implemented). APS considers full-augmented staff as those ERO positions that provide support for the minimum staff in response to an emergency. For Palo Verde, the description of the full-augmented positions, some of which are currently contained in the Palo Verde Emergency Plan, will be relocated to an applicable EPIP. Section 2.1.4, Minimum Staffing, of the enclosure to the LAR identifies the changes to the ERO minimum staff positions, and Section 2.1.5, Full-Augmented Staff, identifies the changes to the full-augmented positions. The NRC staff finds it acceptable to relocate the full-augmented staff positions from the emergency plan to EPIPs because these positions are not needed to implement the emergency plan.

APS stated that it will use additional full-augmentation ERO staff that are trained and qualified.

Most full-augmentation staff will still be assigned to ERO teams, be expected to maintain fitness-for-duty during duty weeks, and be notified to respond to their emergency response facility. The full-augmentation staff performs support functions such as intra-facility communications, organization liaisons, and expert advisors. Full-augmentation staff will not be required to activate a respective emergency response facility and are not directly needed to implement the functions and tasks identified in the revised emergency plan.

Notable Positions Removed:

APS proposed the removal of the engineering director, located in the EOF, and the engineering manager, located in the TSC, from the Palo Verde Emergency Plan. APS provided that the coordination function performed by the engineering director was redundant and unnecessary based on existing communication conduits between the TSC and EOF and that the absence of the engineering manager does not delay the performance of the engineering function as

engineering products would be provided directly to the TSC emergency coordinator. The NRC staff finds it acceptable to remove the engineering director and engineering manager positions from the Palo Verde Emergency Plan.

In the LAR, the licensee stated:

As part of the development of this amendment request, APS conducted a drill to assess the capabilities of the final Minimum Staff personnel. The drill was used to demonstrate that there was not a loss of function due to the changes in the ERO. The drill was critiqued and the issues identified during the drill were entered into the corrective action program. No issue was identified that impacted this submittal.

The licensee further stated:

In addition to validating the change, following approval of this license amendment, PVNGS will conduct a minimum staff drill to ensure that the designated minimum staff is adequate to perform the necessary functions needed to respond to an emergency until the ERO is fully augmented. A minimum staff drill will be conducted at least once every drill cycle (8 years) and the State, NRC and Federal Emergency Management Agency (FEMA) will be provided the opportunity to observe.

As discussed above, the NRC staff determined that the relocation of full-augmentation staff positions from the emergency plan to the EPIPs is acceptable. The revised emergency plan will continue to include those positions necessary for effective implementation of the emergency plan, which will be demonstrated by periodic drills. Based on the above evaluation, the NRC staff concludes that the proposed Palo Verde Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

3.4 Summary The NRC staff performed a technical and regulatory review of the proposed changes to the Palo Verde Emergency Plan. Based on this review, the NRC staff finds that the Palo Verde Emergency Plan, as changed, continues to meet the planning standards of 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Therefore, the NRC staff concludes that the proposed Palo Verde Emergency Plan changes to certain ERO staffing and augmentation times, as described in the application dated October 18, 2019, as supplemented by letter dated March 13, 2020, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the State of Arizona official was notified of the proposed issuance of the amendments on June 8, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the site emergency plan. The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that

may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register on November 19, 2019 (84 FR 63897), and there has been no public comment on such finding. The amendments also relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Lacal, M. L., APS, letter to U.S. Nuclear Regulatory Commission, Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI), Docket Nos. STN50-528, 50-529, 50-530 and 72-44, Renewed Operating License Nos. NPF-41, NPF-51, NPF-74, License Amendment Request for Changes to Emergency Plan Staffing Requirements, dated October 18, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19291F735).

2. Rash, B. J., APS, letter to U.S. Nuclear Regulatory Commission, Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI), Docket Nos. STN50-528, 50-529, 50-530 and 72-44, Renewed Operating License Nos. NPF-41, NPF-51, NPF-74, APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements, dated March 13, 2020 (ADAMS Accession No. ML20073R753).

3. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors, dated October 1981 (ADAMS Accession No. ML090440294).

4. U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980 (ADAMS Accession No. ML040420012).

5. U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (ADAMS Accession No. ML16124A002).

6. Kahler, R. E., U.S. Nuclear Regulatory Commission, letter to Ms. Susan Perkins-Grew, Nuclear Energy Institute, Alternative Guidance for Licensee Emergency Response Organizations, dated June 12, 2018 (ADAMS Accession No. ML18022A352).

7. U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, NUREG-0654/FEMA-REP-1, Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated December 2019 (ADAMS Accession No. ML19347D139).

Principal Contributor: R. Hoffman, NSIR/DPR Date: July 31, 2020

ML20163A037

• by e-mail OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*

NSIR/DPR/RLB/BC*

OGC - NLO*

NAME SLingam PBlechman JAnderson JWachutka DATE 6/16/2020 6/16/2020 6/8/2020 7/6/2020 OFFICE NRR/DORL/LPL4/BC*

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DATE 7/6/2020 7/14/2020 7/31/2020 7/31/2020