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 Verde License Amendment Request for Emergency Plan July 11, 2019

Palo Verde LAR

• 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 (ML18053A159) and approved Safety Evaluation (ML19036A586) for changes to their Emergency Response Organization 2

Palo Verde LAR Critical Elements of License Amendment Request

• No change to current augmentation timeframes and process

• Augment at Alert for all facilities and ERO positions

• Use of an All Call and duty roster process for staffing

• 60 minutes during normal working hours and 120 minutes off hours

• Supplemented Rev. 2 NUREG 0654 on shift ERO to support maintaining 120 minute off hours augmentation

• Increase RP technicians to support onsite or offsite monitoring as needed

• RP Supervision/Dose Assessment on-shift

• Ensure that key ERO functions can be maintained for timeframe prior to augmented resources arrival 3

Palo Verde LAR Critical Elements of License Amendment Request (contd)

• Remove on-shift Chemistry and Maintenance personnel

• Increase number of augmented ERO consistent with guidance in Rev. 2

• Remove non-minimum staff positions from the emergency plan (maintain in procedures)

• State of Arizona has reviewed and supports this amendment request

• State and federal agencies will be invited to a once every drill cycle minimum staff drill 4

Palo Verde LAR Additional 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 time

• Dose Assessment and Radiation Protection leadership available on shift

• Offsite communications to State and Local government and the NRC 5

Palo Verde LAR Additional resources to support the key ERO functions remain in place on shift (contd):

• Engineering Support in the form of the unaffected unit Shift Technical Advisor

• Security 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 Units

• Shift Managers, Control Room Supervisors and Shift Technical Advisors are trained to the Emergency Coordinator position qualification 6

Palo Verde LAR

• Schedule for LAR submittal

• 3rd Quarter 2019

• NRC review and Issuance of Safety Evaluation

• 1 year

• Scheduled Implementation

• Six Months following approval 7

Discussion/Questions