ML070320486

Revision to Emergency Plan to Change Emergency Support Organization Staffing (TAC No. MD2814). Docket No. 50-293

ML070320486
Person / Time
Site:	Pilgrim
Issue date:	02/05/2007
From:	James Kim NRC/NRR/ADRO/DORL/LPLI-1
To:	Kansler M Entergy Nuclear Operations
Kim J, NRR/DORL, 415-4125
References
TAC MD2814
Download: ML070320486 (7)

Text

February 5, 2007 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - REVISION TO EMERGENCY PLAN TO CHANGE EMERGENCY SUPPORT ORGANIZATION STAFFING (TAC NO.

MD2814)

Dear Mr. Kansler:

By letter dated July 14, 2006, (ML062060315), and supplemented by letter dated November 17, 2006, (ML063320549), Entergy Nuclear Operations, Inc., proposed changes to the Pilgrim Nuclear Power Station (PNPS) Emergency Plan. The proposed changes would reduce the number of Radiation Protection Technicians assigned to support on-shift Emergency Support Organization functions.

The Nuclear Regulatory Commission NRC staff has completed a technical and regulatory review of the proposed PNPS Emergency Plan changes and supporting documentation. The NRC staff has concluded that incorporation of the proposed changes do not decrease the effectiveness of the PNPS Emergency Plan and the plan, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to Title 10 Part 50 of the Code of Federal Regulations. The basis for our conclusion is contained in the enclosed safety evaluation. In light of the above, no NRC approval is necessary.

Sincerely, JHughey /RA/ for James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

Safety Evaluation cc w/encl: See next page

February 5, 2007 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - REVISION TO EMERGENCY PLAN TO CHANGE EMERGENCY SUPPORT ORGANIZATION STAFFING (TAC NO.

MD2814)

Dear Mr. Kansler:

By letter dated July 14, 2006, (ML062060315), and supplemented by letter dated November 17, 2006, (ML063320549), Entergy Nuclear Operations, Inc., proposed changes to the Pilgrim Nuclear Power Station (PNPS) Emergency Plan. The proposed changes would reduce the number of Radiation Protection Technicians assigned to support on-shift Emergency Support Organization functions.

The Nuclear Regulatory Commission NRC staff has completed a technical and regulatory review of the proposed PNPS Emergency Plan changes and supporting documentation. The NRC staff has concluded that incorporation of the proposed changes do not decrease the effectiveness of the PNPS Emergency Plan and the plan, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to Title 10 Part 50 of the Code of Federal Regulations. The basis for our conclusion is contained in the enclosed safety evaluation. In light of the above, no NRC approval is necessary.

Sincerely, JHughey /RA/ for James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:

PUBLIC RidsNrrDORLLpl1-1 RidsOgcRP DJohnson LPLI-1 R/F RidsNrrLASLittle RidsAcrsAcnwMailCenter EWeiss RidsNrrPMJShea RidsNrrDORLDpr RidsRgn1MailCenter JMoore Accession No.: ML070320486 OFFICE LPL1-1/PM LPL1-1/PM LPL1-1/LA NSIR/DPR OGC LPL1-1/BC(A)

NAME JHughey JKim SLittle EWeiss JMartin JBoska DATE 2/05/2007 2/05/2007 2/05/2007 2/05/2007 2/05/07 2/05/07 OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO PROPOSED EMERGENCY PLAN CHANGES FOR THE PILGRIM NUCLEAR POWER STATION (PNPS)

1.0 INTRODUCTION

By application letter dated July 14, 2006 (ML062060315), and supplemented by letter dated November 17, 2006 (ML063320549), Entergy Nuclear Operations, Inc. (Entergy), requested changes to the Pilgrim Nuclear Power Station Emergency Plan.

The proposed change would reduce the number of Radiation Protection (RP) Technicians assigned to support on-shift Emergency Support Organization (ERO) functions. This change is intended to reduce the burden of maintaining one on-shift RP Technician over the number of RP Technicians recommended to be acceptable in industry guidelines for providing emergency plan support. This change will allow additional resources to be focused on plant support and improvement activities.

2.0 REGULATORY EVALUATION

The applicable regulations and guidance that the licensee must meet for the emergency plans are as follows:

2.1 Regulations The underlying purpose of the standards in 10 CFR 50.47(b) is to ensure nuclear power reactor licensees have emergency response plans that provide reasonable assurance that adequate protective measures would be taken in the event of an emergency at a nuclear power reactor.

The following regulatory requirements are applicable:

10 CFR 50.47(b)(2): 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, Section IV.A, 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.

Enclosure 2.2 Guidance NRC Regulatory Issue Summary 2005-02, Clarifying the Process for Making Emergency Plan Changes dated February 14, 2005, provides guidance to licensees making changes to their emergency plans.

NUREG-0654/FEMA Rep-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants dated November 1980, provides guidance to licensees in the development of their emergency plans.

3.0 TECHNICAL EVALUATION

The proposed change to the Pilgrim Nuclear Power Station (PNPS) Emergency Plan was evaluated by Entergy Nuclear operations, Inc., (Entergy) and submitted in accordance with 10 CFR 50.4. In its July 14, 2006 letter, Entergy stated that this proposed change will cause the PNPS emergency response organization minimum staffing requirements for on-shift RP and Chemistry Technicians to be consistent NRC guidelines identified in NUREG-0654/FEMA Rep-1, Table B-1 and Regulatory Guide 1.101.

This evaluation is based on revisions to the PNPS Emergency Plan provided in application letter dated July 14, 2006 (ML062060315) as supplemented by letter dated November 17, 2006 (ML063320549). The NRC staff has reviewed the technical and regulatory analysis in support of the proposed changes. The proposed changes to the PNPS Emergency Plan would change the number of on-shift RP Technicians from two to one. The initial PNPS Emergency Plan, issued on 1982, conservatively established a requirement to have two RP Technicians on-shift to support the Operations Accident Assessment Support Functional Area. The basis for this requirement was not documented by the licensee. NUREG-0654/FEMA Rep-1 recommends that one RP Technician be assigned on-shift.

Subsequent to the establishment of the initial PNPS Emergency Plan, functional responsibilities of the on-shift Chemistry Technician have been significantly reduced. This workload reduction resulted from elimination of the requirements to obtain Post Accident chemistry samples during the initial phase of emergency events. The licensees basis for this change is provided in PNPS License Amendment No. 204, dated November 14, 2003, and NRC Safety Evaluation dated June 12, 2001 (ML011630016), for BWR Owners Group Topical Report NEDO 32991, Regulatory Relaxation for BWR [Boiling-Water Reactor] Post Accident Sampling Stations (ML003781582).

With this reduction in the responsibilities of the on-shift Chemistry Technician, the on-shift Chemistry Technician is available to support PNPS Emergency Plan RP functions. The on-shift Chemistry Technician will be qualified to perform specific PNPS Emergency Plan RP tasks involving in-plant surveys, access control, personnel monitoring, and issuance of dosimetry.

The reduction of the on-shift RP Technicians from two to one is in alignment with the guidance of NUREG-0654/FEMA Rep-1. Furthermore, the qualification of the on-shift Chemistry Technician to support specific RP tasks is seen as an enhancement to the ability of the PNPS to provide RP coverage during the initial stages of an emergency event.

4.0 CONCLUSION

The NRC staff performed a technical and regulatory review of the proposed changes to the PNPS Emergency Plan. The staff has determined that incorporation of the proposed changes do not decrease the effectiveness of the PNPS Emergency Plan and the plan, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.

5.0 REFERENCES

1.

PNPS Letter No. 2.05.086, Emergency Plan Changes to the Minimum Staffing Requirements for the Emergency Response Organization (ERO), dated July 14, 2006.

[ADAMS Accession No. ML062060315]

2.

PNPS Letter No. 2.06.097, Response to NRC Request for Additional Information Regarding Emergency Plan Changes to the Pilgrim Nuclear Power Station Emergency Response Organization, dated November 17, 2006. [ADAMS Accession No. ML063320549]

3.

NUREG-0654/FEMA Rep-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]

4.

BWR Owners Group Topical Report NEDO 32991, Regulatory Relaxation for BWR Post Accident Sampling Stations. [ADAMS Accession No. ML003781582]

5.

NRC SER for NEDO 32991, Regulatory Relaxation for BWR Post Accident Sampling Stations. [ADAMS Accession No. ML011630016]

Principal Contributor: Michael Norris Date: February 5, 2007

Pilgrim Nuclear Power Station cc:

Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Senior Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360 Chairman, Board of Selectmen 11 Lincoln Street Plymouth, MA 02360 Chairman Nuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360 Chairman, Duxbury Board of Selectmen Town Hall 878 Tremont Street Duxbury, MA 02332 Office of the Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 MA Department of Public Health Radiation Control Program Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129 Secretary of Public Safety Executive Office of Public Safety One Ashburton Place Boston, MA 02108 Director, Massachusetts Emergency Management Agency Attn: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426 Mr. Kevin H. Bronson General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Michael A. Balduzzi Site Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Stephen J. Bethay Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Bryan S. Ford Manager, Licensing Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508