ML030830543

Proposed Emergency Plan Changes

ML030830543
Person / Time
Site:	Susquehanna
Issue date:	03/24/2003
From:	Richard Guzman NRC/NRR/DLPM/LPD1
To:	Shriver B Susquehanna
Guzman R, NRR/DLPM 415-1030
References
TAC MB6300, TAC MB6301
Download: ML030830543 (26)

Text

March 24, 2003 Mr. Bryce L. Shriver Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - PROPOSED EMERGENCY PLAN CHANGES (TAC NOS. MB6300 AND MB6301)

Dear Mr. Shriver:

By letter dated September 6, 2002, as supplemented by letters dated January 6 and 10, and February 7, 2003, PPL Susquehanna, LLC, submitted proposed changes to the Susquehanna Steam Electric Station, Unit Nos. 1 and 2 (SSES-1 and 2), Emergency Plan for Nuclear Regulatory Commission (NRC) review and approval prior to implementation in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(q).

The proposed changes can be summarized as follows: (1) revise the minimum on-shift staffing levels, (2) revise two column headings for Table 6.1, "Station Emergency Plan Minimum Staffing Requirements" from 30 to 60 minutes to 60 minutes and from 60 to 90 minutes to 90 minutes, (3) clarify engineering roles and responsibilities in all emergency response facilities (ERFs), (4) allow an emergency director to relieve the shift supervisor/shift manager as emergency director independent of technical support center activation, (5) clarify the minimum required ERF staffing, and (6) revise emergency action levels associated with radiological effluents.

Based on its review, the NRC staff has concluded that the proposed SSES-1 and 2 Emergency Plan changes do not decrease the effectiveness of the Emergency Plan and that the plan, as changed, continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. As agreed to by your staff, the SSES-1 and 2 Emergency Plan changes involving the control room communicator and the operational support center coordinator shall be implemented within 30 days from the issuance date of this letter. All other changes shall be implemented by June 30, 2003.

On February 25, 2002, NRC issued an Order modifying the operating license for SSES-1 and 2 to require compliance with the interim safeguards and security compensatory measures listed in to the Order. Please note that in case of conflicts between the changes approved by this letter and the requirements contained in the Order transmitting the interim compensatory measures, the requirements of the Order take precedence.

B. Shriver The details of the NRC staffs review are contained in the enclosed safety evaluation. If you have any questions, please contact me at 301-415-1030.

Sincerely,

/RA/

Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

Safety Evaluation cc w/encl: See next page

B. Shriver The details of the NRC staffs review are contained in the enclosed safety evaluation. If you have any questions, please contact me at 301-415-1030.

Sincerely,

/RA/

Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION PUBLIC PDI-1 RF RLaufer RGuzman ACRS TBlount MOBrien BMoody KGibson PMulligan OGC BPlatchek, RGN-1 DOCUMENT NAME:C:\ORPCheckout\FileNET\ML030830543.wpd ACCESSION NO.: ML030830543, Tables & Charts: ML ,Package: ML

• SE provided. No substantive changes.

OFFICE PDI-1/PM PDI-2/LA IEHB/SC* PDI-1/SC NAME RGuzman OBrien, SLittle for MO'Brien KGibson RLaufer DATE 3/21/03 3/21/03, 3/5/03 02/25/03 SE DTD 3/24/03 OFFICIAL RECORD COPY

Susquehanna Steam Electric Station, Units 1 &2 Bryce L. Shriver Allentown, PA 18101-1179 Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC Dale F. Roth 769 Salem Blvd., NUCSB3 Manager - Quality Assurance Berwick, PA 18603-0467 PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Richard L. Anderson Berwick, PA 18603-0467 Vice President - Nuclear Operations PPL Susquehanna, LLC Herbert D. Woodeshick 769 Salem Blvd., NUCSB3 Special Office of the President Berwick, PA 18603-0467 PPL Susquehanna, LLC 634 Salem Blvd., SSO Aloysius J. Wrape, III Berwick, PA 18603-0467 General Manager - Nuclear Assurance PPL Susquehanna, LLC Bryan A. Snapp, Esq Two North Ninth Street, GENA92 Assoc. General Counsel Allentown, PA 18101-1179 PPL Services Corporation Two North Ninth Street, GENTW3 Terry L. Harpster Allentown, PA 18101-1179 General Manager - Plant Support PPL Susquehanna, LLC Supervisor - Document Control Services 769 Salem Blvd., NUCSA4 PPL Susquehanna, LLC Berwick, PA 18603-0467 Two North Ninth Street, GENTW3 Allentown, PA 18101-1179 Robert A. Saccone General Manager - Nuclear Engineering Richard W. Osborne PPL Susquehanna, LLC Allegheny Electric Cooperative, Inc.

769 Salem Blvd., NUCSB3 212 Locust Street Berwick, PA 18603-0467 P.O. Box 1266 Harrisburg, PA 17108-1266 Rocco R. Sgarro Manager - Nuclear Regulatory Affairs Director - Bureau of Radiation Protection PPL Susquehanna, LLC Pennsylvania Department of Two North Ninth Street, GENA61 Environmental Protection Allentown, PA 18101-1179 P.O. Box 8469 Harrisburg, PA 17105-8469 Curtis D. Markley Supervisor - Nuclear Regulatory Affairs Senior Resident Inspector PPL Susquehanna, LLC U.S. Nuclear Regulatory Commission 769 Salem Blvd., NUCSA4 P.O. Box 35, NUCSA4 Berwick, PA 18603-0467 Berwick, PA 18603-0035 Michael H. Crowthers Regional Administrator, Region 1 Supervising Engineer U.S. Nuclear Regulatory Commission Nuclear Regulatory Affairs 475 Allendale Road PPL Susquehanna, LLC King of Prussia, PA 19406 Two North Ninth Street, GENA61

Susquehanna Steam Electric Station, Units 1 &2 Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EMERGENCY PLAN CHANGES PPL SUSQUEHANNA, LLC SUSQUEHANNA STEAM ELECTRIC STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-387 AND 50-388

1.0 INTRODUCTION

In its application dated September 6, 2002, as supplemented by the letters dated January 6 and 10, and February 7, 2003, PPL Susquehanna, LLC (PPL, the licensee), submitted changes to the Susquehanna Steam Electric Station, Unit Nos. 1 and 2 (SSES-1 and 2), Emergency Plan for Nuclear Regulatory Commission (NRC) review and approval prior to their implementation in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(q). The key proposed changes are as follows: (1) revise the minimum on-shift staffing levels, (2) revise two column headings for Table 6.1, "Station Emergency Plan Minimum Staffing Requirements,"

from 30 to 60 minutes to 60 minutes and from 60 to 90 minutes to 90 minutes, (3) clarify engineering roles and responsibilities in all emergency response facilities (ERFs), (4) allow an emergency director to relieve the shift supervisor/shift manager as emergency director independent of technical support center (TSC) activation, (5) clarify the minimum required ERF staffing, and (6) revise emergency action levels (EALs) associated with radiological effluents.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance for which the NRC staff considered in its review of the application are as follows:

2.1 Regulations Section 50.47(b)(1) states, in part, ... and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Section 50.47(b)(2) states, in part, "... 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 ..."

Section 50.47(b)(4) states A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determination of minimum initial offsite response measures.

Section 50.47(b)(8) states "Adequate emergency facilities and equipment to support the emergency response are provided and maintained."

Section 50.47(b)(9) states: Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

2.2 Guidance Regulatory Guide (RG) 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 3, states, in part, "The criteria and recommendations contained in Revision 1 of NUREG-0654/FEMA [Federal Emergency Management Agency]-REP-1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47 that must be met in on-site and off-site emergency response plans."

RG 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, Revision 3, endorsed NUMARC-007, Methodology for Development of Emergency Action Levels," as an acceptable alternative to NUREG-0654 for developing EAL schemes.

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, states in:

Section II.B, Onsite Emergency Organization," part 5, Each licensee shall specify ... functional areas of emergency activity. . .

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 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 . . .

Section Il.D, Emergency Classification System, part 1, An emergency classification and emergency action level scheme as set forth in Appendix 1must be established by the licensee.

Section ll.D, Emergency Classification System, part 2, The initiating conditions shall include the example conditions found in Appendix 1 [of NUREG-0654]...

Section II.H, Emergency Facilities and Equipment, part 1, Each licensee shall establish a Technical Support Center ... in accordance with NUREG-0696, Revision 1.

Section II.H, Emergency Facilities and Equipment, part 2, Each licensee shall establish an Emergency Operations Facility ... in accordance with NUREG-0696, Revision 1.

Section II.I, Accident Assessment, part 8, Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards . . . This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.

NUREG-0696, Revision 1, Functional Criteria for Emergency Response Facilities, states, in part, in subparagraph 2.3., "Upon activation of the TSC [Technical Support Center], ... achieve full functional operation within 30 minutes, and in subparagraph 4.3., "Upon EOF [Emergency Operations Facility] activation, ... achieve full functional operation within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

NUREG-0737, Supplement 1, "Clarification of TMI Action Plan Requirements,"

states in:

Section 8.2.1.a, "The TSC [Technical Support Center] will perform EOF functions for the Alert Emergency class and for the Site Area Emergency class and General Emergency class until the EOF is functional."

Section 8.2.1.j, "TSC ... be fully operational within approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after activation.

Section 8.4.1.j, "EOF. . . Staffed using Table 2 [previous guidance approved by the Commission] as a goal. Reasonable exceptions to goals for the number of additional staff personnel and response times for their arrival should be justified and will be considered by NRC staff.

The applicable regulation for making changes to a licensee's emergency plan is 10 CFR 50.54(q). This regulation states that licensees may change their radiological emergency plan without NRC approval only if the changes do not decrease the effectiveness of the plan, and the plan, as changed, continues to meet the planning standards of paragraph 50.47 and the requirements of Appendix E to 10 CFR Part 50. PPL states in their application dated September 6, 2002, that as a result of a full assessment of the Susquehanna Emergency Plan, PPL determined via 10 CFR 50.54(q) that some of the proposed Emergency Plan changes required NRC approval prior to implementation. Therefore, PPL submitted the proposed changes to the NRC in the application dated September 6, 2002.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of its proposed emergency plan changes, which are described in their application dated September 6, 2002, as supplemented in letters dated January 6 and 10, and February 7, 2003.

The detailed evaluation below supports the conclusion 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) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed emergency plan changes will not be inimical to the common defense and security or to the health and safety of the public.

The NRC staff evaluated the proposed changes in the following order: (1) revise the minimum on-shift staffing levels, (2) revise two column headings for Table 6.1, "Station Emergency Plan Minimum Staffing Requirements," from 30 to 60 minutes to 60 minutes and from 60 to 90 minutes to 90 minutes, (3) clarify engineering roles and responsibilities in all ERFs, (4) allow an emergency director to relieve the shift supervisor/shift manager as emergency director independent of TSC activation, (5) clarify the minimum required ERF staffing, and (6) revise EALs associated with radiological effluents.

3.1 Revise the minimum on-shift staffing levels PPL proposes nine specific changes to the on-shift positions assigned emergency response functions. Each of the proposed changes is discussed in the following sections.

3.1.1 Reduce the number of unit supervisors to one - PPLs justification The second unit supervisor has no specific role or responsibility for emergency plan response in the SSES-1 and 2 Emergency Plan. NUREG-0654 guidance provides that units having a common control room may share a shift foreman if all functions are covered. The second unit supervisor role was to provide direction and guidance to the plant control operator (PCO) on the unaffected unit. This direction and guidance to the PCO would still continue to be provided by the one unit supervisor and the shift manager who are part of the minimum staffing requirements. In a scenario that could affect both units, such as a loss of offsite power or certain security-related events, both units would undergo a shutdown transient. If one of the units experienced additional problems, that unit would have two PCOs to deal with that situation. The third PCO would still be able to take the necessary actions to stabilize the second unit. The shift manager as emergency director would provide direction to the control room crew and the one unit supervisor, with assessment and technical support from the shift technical advisor, would provide additional necessary guidance to the operators. During two scenarios that were recently conducted in the SSES-1 and 2 simulator, crew performance demonstrated that a single PCO was capable of performing the required actions to stabilize the unit with limited direction and guidance provided by the unit supervisor.

NRC Staffs Evaluation Guidance provided in the footnotes to Table B-1 of NUREG-0654 states that units sharing a control room may share a shift foreman if all functions are covered. PPLs justification is consistent with this guidance. Therefore, the proposed change is acceptable.

3.1.2 Remove the reference to the auxiliary unit supervisor as a fire brigade leader - PPLs justification In addition to the emergency response role of operational support center (OSC) coordinator, the auxiliary unit supervisor could also serve as a fire brigade leader. This change to the SSES-1 and 2 Emergency Plan proposes to replace the requirement for an on-shift auxiliary unit supervisor to serve as a fire brigade leader with a commitment to provide an on-shift qualified fire brigade leader per the Technical Requirements Manual (TRM). This change avoids potential confusion caused by specifying licensing requirements in multiple documents. It was never the intent that the SSES-1 and 2 Emergency Plan would drive the requirements for fire response. Those requirements are contained in the Fire Protection Review Report and the TRM.

NRC Staffs Evaluation Removing the reference to the auxiliary unit supervisor as a fire brigade leader and referencing that fire brigade response personnel are designated in the TRM does not reduce the effectiveness of the SSES-1 and 2 Emergency Plan. The proposed change is therefore acceptable.

3.1.3 Change the OSC coordinator position from an on-shift response to a 60-minute response - PPLs justification As an on-shift response position under the existing plan, the shift manager would assign an OSC coordinator from the on-shift crew. This resulted in using an operator who may be better used in another capacity to deal with the event. During the early stages of an event (prior to TSC activation), the emergency response capability consists of the on-shift complement of personnel. These personnel typically receive direction from the control room to perform necessary operating functions. Establishing an OSC coordinator for immediate emergency response creates additional communication requirements that are different from the routine operator communications and could encumber the response of the on-shift crew to the event.

The most efficient use of resources and response of the on-shift crew is through direct communication from the control room to the on-shift response personnel. The change to the OSC position deletes an extra in-line communication from the control room to the OSC coordinator and then to the field operators/support personnel at a time when accurate and timely communication is essential. The shift manager is no longer tasked with assigning an individual to this position, thus providing an additional on-shift resource that may be assigned other response activities.

Reviewing the SSES-1 and 2 Emergency Plan revision history did not provide any reason for the OSC coordinator being an on-shift response position. The original position of the on-shift OSC coordinator was established as a result of having additional personnel available on shift beyond that which was required by regulation. There was no specific defined regulation or station need to establish an on-shift OSC coordinator.

As part of operator training, plant scenarios are established that require entry into the SSES-1 and 2 Emergency Plan and the appropriate shift crew response is demonstrated. During these scenarios, the position of OSC coordinator is not used. Direct communication to in-field

operators are simulated by the on-shift crew to the instructor in the simulator control booth.

Under the proposed revision, the control room maintains effective accident response and mitigation by support personnel until the damage control team coordinator and the OSC coordinator arrive in the TSC and OSC. At an alert or higher level classification, additional support personnel arrive resulting in the need for a more dedicated effort to control and track response teams. At this same time, the TSC assumes control of in-plant teams thus relieving the control room of this responsibility.

The response of the damage control team coordinator upon TSC activation remains unchanged and provides the appropriate assistance to the control room by coordinating the damage control actions of the additional emergency response personnel. The addition of the OSC coordinator to the TSC response provides additional support for the management and control of the emergency response staff without using on-shift operating personnel. It also ensures there is a management position in the OSC.

NRC Staffs Evaluation The guidance in Table B-1 of NUREG-0654 does not specify the need for the position of OSC coordinator. The NRC staff finds the justification provided by PPL to change the on-shift OSC coordinator position to a 60-minute time response position to be acceptable.

3.1.4 Delete the auxiliary unit supervisor position - PPLs justification The position of auxiliary unit supervisor is proposed to be deleted from the required on-shift manning for emergency response. The auxiliary unit supervisor has filled the SSES-1 and 2 Emergency Plan role of the OSC coordinator unless required to perform the duties of the fire brigade leader which is required by the TRM. The position of OSC coordinator is being changed from an on-shift response to a 60-minute response.

NRC Staffs Evaluation Since PPLs justification for changing the on-shift position of OSC coordinator to a 60-minute response position was determined to be acceptable as discussed in safety evaluation (SE) section 3.1.3 above, and PPL has provided sufficient compensation for the two designated emergency response functions assigned to the auxiliary unit supervisor (OSC coordinator and fire brigade leader) in SE sections 3.1.2 and 3.1.3, the NRC staff finds the proposed change acceptable.

3.1.5 Add one qualified control room communicator and reduce the number of PCOs to three - PPLs justification In the past revisions of the SSES-1 and 2 Emergency Plan, a fourth PCO was required and was designated to become the control room communicator. In the proposed revision, the position of control room communicator is separately identified as a required minimum staffing position.

The change allows the use of someone other than a PCO, who is properly trained and qualified, to perform the function of control room communicator. The requirement to staff with three PCOs is consistent with the plant Technical Specifications and the guidance of NUREG-0654.

The proposed staffing requirement for a control room communicator would still ensure that the communication function is performed immediately upon entering the SSES-1 and 2 Emergency Plan.

NRC Staffs Evaluation PPL has proposed to replace a PCO who had been designated to perform the function of control room communicator with someone else on shift, who is trained and qualified to perform that function. The proposed changes are acceptable.

3.1.6 Clarify the responsibilities to be performed by non-licensed operators (NLOs) - PPLs justification The position titles of nuclear plant operator and auxiliary systems operator had been used to identify NLO roles in the normal operating organization. These NLO titles were combined into one consistent NLO function. The revised Table 6.1 now requires three NLOs for SSES-1 and 2 Emergency Plan support with a separate entry for fire brigade members (i.e. two NLOs). NUREG-0654 guidance requires two NLOs for the affected unit and one NLO for the unaffected unit. The proposed staffing level is consistent with the Final Safety Analysis Report, Section 13.1.2.3, Technical Specification 5.2.2, and Technical Requirement 4.1.2 (regarding the site fire brigade).

PPL originally proposed the use of three NLOs to perform repair and corrective action tasks. In their letter dated January 6, 2003, PPL proposed the addition of another NLO. Having four NLOs provides sufficient flexibility such that corrective actions can be taken by NLOs on-shift until additional support arrives. In the first hour of an emergency, PPLs strategy focuses on mitigating and containing the problem that caused the emergency. Mitigating or containing the problem typically involves activities such as racking breakers, changing fuses, manipulating valves, moving equipment, and starting equipment locally. The NLOs are trained on these duties and perform these actions frequently as part of their daily activities. A footnote was also proposed to be added to Table 6.1 to list these duties.

During many emergencies, Operations uses the symptom-based emergency operating procedures (EOPs). These procedures are specifically designed to mitigate or contain the problem, not to diagnose it or effect repairs. In addition, Operations has developed emergency support (ES) procedures for a variety of actions including bypassing trip signals from instrumentation. The material and tools for these procedures is pre-staged and installation locations are color coded to aid the operator in locating specific points to install jumpers or other devices. The NLOs receive training on these procedures annually.

NRC Staff Evaluation

PPL proposes to clarify the title of the NLO and the tasks that may be performed in the event of an emergency such as racking breakers, changing fuses, manipulating valves, moving equipment, and starting equipment locally to mitigate or contain the problem during the first hour of an emergency. Since the proposed changes do not decrease the effectiveness of the SSES-1 and 2 Emergency Plan, the changes are acceptable.

3.1.7 Change the number of health physics (HP) technicians from one per unit to two in total - PPLs justification The number of HP technicians was not revised. Designation of a total number of HP technicians is an administrative change reflecting consideration of these positions on a station

basis rather that on a per-unit basis. There is no reduction in the total numbers committed for this position.

NRC Staffs Evaluation Since this is an administrative change and does not reduce the effectiveness of the SSES-1 and 2 Emergency Plan, the proposed change is acceptable.

3.1.8 Add an NRC Communicator - PPLs Justification PPL stated in their supplemental letter dated January 6, 2003, that in reviewing past drill data as well as lessons learned from recent Emergency Plan activations, performance overall has been satisfactory. However, one area for improvement that was noted was communications with the NRC during the initial stages of an event. Accordingly, PPL proposed to add a new position for this function. PPL proposed to call this position NRC communicator and structure it similar to the NRC communications responsibilities performed by the TSC communicator.

The qualifications required for the NRC communicator are that the individual must have sufficient understanding of control room operations and that they can provide information concerning critical plant parameters, resources available to deal with the event, procedures in use, priorities and actions to minimize the consequences of the event. These qualifications would normally be met with someone that holds or has held an NRC license or shift technical advisor (STA) certification at SSES-1 and 2 or other Boiling-Water Reactor (BWR) facility or has been certified at SSES-1 and 2 or other BWR facility. In lieu of license or certification, the individual will have sufficient BWR operating experience as determined by the manager-nuclear operations to facilitate accurate communication with the NRC. Such individuals may be reactor engineers, simulator instructors or individuals from the operations staff.

NRC Staff Evaluation

The NRC staff finds PPL's justification sufficient to warrant the addition of the NRC communicator to the minimum on-shift emergency response staffing level. The addition of another communicator provides a dedicated person to communicate with the NRC and allow other on-shift personnel cross-qualified to perform the communicator function to perform other emergency response functions they may be qualified to perform. Therefore, the proposed change is acceptable.

3.1.9 Revise the on shift dose assessment capability - PPL's justification In their supplemental letter dated January 6, 2003, PPL stated that the on-shift personnel assigned the dose assessment function would receive the same training and annual retraining as the personnel assigned the dose assessment function in the TSC. To augment the on-shift dose assessment capability, PPL's proposed revision to Table 6.1 shows one rad assessment staff member as a 60-minute responder and two additional rad assessment staff members as 90-minute responders, as well as a dose assessment supervisor as a 90-minute responder.

NRC Staff Evaluation

NUREG-0654, Table B-1, specifies the capability to provide one person with senior health physics expertise to perform offsite dose assessment within 30 minutes. PPL proposes to provide the same training for on-shift personnel who perform the dose assessment function as those who perform the similar function in the TSC and augmentation of the dose assessment capability in 60 and 90 minutes. The NRC staff finds the compensation described above to be acceptable.

3.1.10 Summary of on-shift staffing changes In their supplemental letter dated January 6, 2003, PPL added two positions over that proposed in their original application. These additions increase the total number of on-shift individuals in their proposed SSES-1 and 2 Emergency Plan to 15 positions (excluding fire brigade personnel and security personnel).

Also, PPL proposes to implement the following two changes within 30 days of NRC approval:

1. The change to go from four PCOs to three PCOs and an emergency plan communicator.

2. The change to move the OSC coordinator from an on-shift position to a 60-minute responder.

In addition, PPL proposes to implement the rest of the proposed SSES-1 and 2 Emergency Plan changes by June 30, 2003.

In their supplemental letter dated January 6, 2003, PPL also stated that during this two-phase approach, staffing will be maintained at 15 positions (excluding fire brigade personnel and security personnel) as illustrated below:

Staffing Within 30 Days of NRC Approval 1 Shift Manager (SRO) 2 Unit Supervisors (SRO) 3 Plant Control Operators (RO) 4 Non-Licensed Operators 1 Shift Technical Advisor 2 Health Physics Technicians 1 Chemistry Technician 1 Emergency Plan Communicator 15 Staffing By June 30, 2003 1 Shift Manager (SRO) 1 Unit Supervisor (SRO) 3 Plant Control Operators (RO) 4 Non-Licensed Operators

1 Shift Technical Advisor 2 Health Physics Technicians 1 Chemistry Technician 1 Emergency Plan Communicator 1 NRC Communicator 15 Additional personnel are available on-shift for fire brigade and security functions. Fire brigade personnel are as specified in the TRM and security personnel are as specified in the SSES-1 and 2 Security Plan. Therefore, the plan described above, to implement the proposed changes to the SSES-1 and 2 Emergency Plan in two phases, is acceptable.

3.2 Revise two-column headings for Table 6.1, "Station Emergency Plan Minimum Staffing Requirements," from 30 to 60 minutes to 60 minutes and from 60 to 90 minutes to 90 minutes The current SSES-1 and 2 Emergency Plan specifies the response times for certain tasks as 30 to 60 minutes and 60 to 90 minutes. The proposed change to Table 6.1 will revise the response times for augmentation personnel to 60 minutes in lieu of the current 30-to 60-minute response time and to 90 minutes in lieu of the current 60-to 90-minute response time. PPL proposes to combine two existing tables associated with emergency response staffing levels and capabilities into one table. The intent of combining the tables is to clearly define the minimum staffing levels and to create a table that more closely matches the guidance provided in Table B-1 of NUREG-0654.

The following is PPLs justification for proposing the changes followed by the NRC staff evaluation of the compensation provided.

3.2.1 Partial compensation for extending emergency response positions - PPLs justification In their supplemental letter dated January 6, 2003, PPL states that management expectations related to the emergency response organization reporting in the event of an emergency were communicated to all personnel in a letter dated November 8, 2001. Included in these expectations is a requirement for on-call personnel to immediately report upon receiving an unscheduled 22222 pager activation (indicating a requirement to respond). These expectations are also captured in department procedure, NDAP-QA-0014, "Nuclear Department Call-out Procedure."

Also, in the letter dated January 6, 2003, PPL states that when an Alert classification is declared, the control room initiates pager activation via a single pushbutton in the control room.

The pagers go off typically less than 1 minute after the button is pushed. On-call personnel respond immediately to their assigned facility. As a backup, the control room contacts security who activates an automated call-out system. The system sends a second page. Nuclear Emergency Response Organization (NERO) personnel not on-call, but fit for duty and at a location within the required response time, call in. The first person to call in for each position is expected to respond to their assigned facility. As a result more than one person for each position will respond to the pager activation. If no one calls in within 10 minutes for a given

NERO position, then the system automatically calls the people assigned to the position (work phone, home phone, and/or their cell phone). After the facilities are fully functional, extra personnel will be released or retained to help as conditions dictate. If the emergency continues, additional personnel are scheduled for subsequent shifts via various administrative functions within the TSC, Media Operations Center, and EOF.

In addition to the processes described above for NERO personnel, there are provisions to call out maintenance workers and health physics technicians as needed. Management personnel from these areas are on-call and these individuals respond as outlined above. These individuals arrange for call-out of additional personnel as needed.

NRC Staff Evaluation

PPLs requirement for all emergency response organization personnel to report immediately upon being notified provides part of the basis for extending emergency augmentation staff response times.

3.2.2 Repair and corrective actions tasks - PPLs justification In supplemental letter dated January 6, 2003, PPL proposes to augment the on-shift staff with one mechanical maintenance/radwaste operator and one electrical maintenance/instrument and control technician within 60 minutes to perform repair and corrective action function. Also, PPL proposes an electrical maintenance/instrument and control technician as a 90-minute responder. PPL also proposes a damage control team coordinator, an OSC coordinator, and a TSC radio coordinator as 60-minute responders. In addition, PPL has proposed a footnote to Table 6.1 which states that on-shift NLOs can provide initial damage control repair activities until additional support arrives. Such activities include racking breakers, changing fuses, manipulating valves, moving equipment, and starting equipment locally.

NRC Staff Evaluation

Table B-1 of NUREG-0654 specifies the following shift augmentation positions for repair and corrective actions: two electrical maintenance/instrument and control technicians as 30-minute responders and two mechanical maintenance/radwaste operators and one electrical maintenance/instrument and control technicians as 60-minute responders. While the response times and numbers of responders proposed by PPL differ from those in Table B-1 of NUREG-0654, the compensation provided by the on-shift repair and corrective action capability provided by the NLOs, the damage control team coordinator, OSC coordinator, and TSC radio coordinator, who respond within 60 minutes, and established management expectations for immediate response as discussed in SE section 3.2.1, provide a sufficient basis to find the proposed changes acceptable.

3.2.3 Offsite survey teams - PPLs justification In the letter dated September 6, 2002, PPL states that the reallocation of the offsite survey personnel commitment has increased the number of 60-minute responders by two, with a corresponding reduction in the number of 90-minute responders.

NRC Staff Evaluation

The reallocation of HP technicians assigned to offsite survey teams meets the guidance provided in Table B-1 of NUREG-0654 except for the response times. However, as compensation, PPL has one more on-shift HP technician than specified in Table B-1 of NUREG-0654, increases the number of 60-minute responders, and establishes management expectations for immediate response as discussed in SE section 3.2.1. Therefore, the proposed change is acceptable.

3.2.4 Radiation protection, and in-plant and onsite (out-of-plant) survey tasks performed by HP technicians - PPLs justification In the letter dated September 6, 2002, PPL states that the commitment for a total of four qualified HP technicians in the 60-minute response time remains unchanged. However, the allocation of these resources among functions has been modified. The total number of HP technicians for this time-frame in the broad function of radiation protection and dose assessment has been increased from two to three. A corresponding reduction from two to one is proposed in the total number of HP technicians identified for the task of onsite (out-of-plant) surveys.

Similarly, the commitment for a total of four qualified HP technicians in the 90-minute response time remains unchanged. However, the allocation of these resources among functions has also been modified. The total number of HP technicians identified for this time-frame in the broad function of radiation protection and dose assessment has been increased from two to three. A corresponding reduction from two to one is also proposed in the total number of HP technicians identified for the task of on-site (out-of-plant) surveys.

In their supplemental letter dated January 6, 2003, PPL also states that the two on-shift health physics technicians fulfill health physics coverage requirements. The duties and priorities of the technicians depend on the nature of the emergency.

Over a period of time, SSES-1 and 2 has taken advantage of technological advances to automate some processes that previously were performed manually. In their supplemental letter dated January 6, 2003, PPL states that during most emergency plan scenarios, access control and dosimetry issue are performed automatically via the Radiation Protection Module and Real Time Dose Tracking System (RAXX) of the Nuclear Information Management System (NIMS). RAXX is fed by an uninterruptable power supply (UPS) that is designed to provide uninterrupted power for a minimum of 60 minutes. In addition, in the event the lead RAXX server fails, the system automatically switches to a backup server with no loss of data. The readers used to issue dosimetry are fed by UPS power on Unit 2 (the main access point) while two readers on Unit 1 are fed by UPS power.

Personnel monitoring is performed with personnel contamination monitors (PCMs) and portal monitors. Handheld material is monitored with small article monitors (SAMs). The PCMs at the Unit 2 access point are supplied with a UPS. The portal and SAMs on Unit 2 are fed by the same power supply. In addition, these devices have an internal battery that is capable of supplying the monitors for 3 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> depending on use. On Unit 1, the PCMs do not have a UPS. The Unit 1 Portal and SAMs have internal batteries good for 3 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

NRC Staff Evaluation

PPL has combined their discussion of the following HP technician tasks: onsite (out-of-plant) surveys, in-plant surveys, dose assessment, access control, HP coverage for repair and corrective actions, search and rescue, first aid, firefighting, personnel monitoring, and dosimetry. In the proposed Table 6.1, PPL identifies four HP technicians as 60-minute responders and another four within 90 minutes to perform these tasks. However, the compensation provided for extending the response time for the senior HP expertise position within 30 minutes was discussed in SE section 3.1.9. The remaining tasks involving radiation protection are discussed below.

In the past, licensees have discussed and proposed the use of technological advances in radiation monitoring, instead of relying on effective on-scene HP job coverage for emergency entry teams. During the initial response period of an accident, the normal pre-work HP survey of the work area is, in most cases, not an acceptable method (it can take too long for the HP technician to perform the survey and then report back to brief the workers). Given the inherent nature of accidents, the work area conditions could have significantly and unpredictably changed by the time the workers arrive. In the vast majority of plant locations, installed radiation monitoring equipment is not adequate alone (or not present) to satisfy the evaluation need. Additionally, such equipment may not be operational or reliable. Merely equipping each worker with an electronic dosimeter (ED) (without an accompanying HP technician) is not an adequate, stand-alone method to satisfy the survey requirement. EDs do provide dose and dose rate alarms, but experience shows clearly that in high noise areas, these alarms are not easily heard. During normal, non-emergency conditions, workers have ignored these alarms, many ED designs are not qualified for high heat/humidity conditions, their relatively small displays may not be visible in high humidity conditions, and EDs should not be used as survey instruments (see RG 8.28, Audible-Alarm Dosimeters). Also, during normal, stable operations, the typical plant HP controls for entering and working in high radiation areas do not allow worker entry into areas with unknown radiation levels. However, EDs do provide an additional level of protection for the worker by offering an electronic time-keeping backup and alerting a worker to a change in radiation levels.

PPL has basically extended the response times from 30 and 60 minutes to 60 and 90 minutes, respectively. Compensation to extend the response times for individuals performing these tasks includes: providing a HP technician above what is specified in NUREG-0654 for a total of two HPs on-site, and the management expectations for immediate response as discussed in SE section 3.2.1. Therefore, the proposed changes are acceptable.

3.2.6 - Chemistry augmentation - PPL's justification In the letter dated September 6, 2002, PPL proposes to augment the on-shift staff with one chemistry/radiochemistry person within 60 minutes. This is consistent with the guidance provided in Table B-1 of NUREG-0654.

NRC Staff Evaluation

NUREG-0654, Table B-1, specifies one on-shift chemistry/radiochemistry person and the capability to augment that position with an additional chemistry/radiochemistry person within 60 minutes. Therefore, the change is acceptable.

3.2.7 Technical support tasks - PPLs justification In the letter dated September 6, 2002, PPL proposed the following six positions as 60-minute responders - operations coordinator, core/thermal hydraulics, electrical, mechanical, technical support coordinator, and the severe accident coordinator. PPL also proposed one 90-minute responder which was the engineering support supervisor. These positions meet or exceed the guidance provided in Table B-1 of NUREG-0654, with the exception of the core/thermal hydraulics position, which is proposed as a 60-minute responder rather than a 30-minute responder.

NRC Staff Evaluation

NUREG-0654, Table B-1, specifies the capability to provide one person with core/thermal hydraulics expertise within 30 minutes and two more individuals with electrical and mechanical expertise within 60 minutes. The staffing level proposed by PPL meets or exceeds this guidance except the core/thermal hydraulics expertise within 30 minutes position. Since the STA duties normally encompass the core/thermal hydraulics function, it is reasonable to assume the STA would perform that function for another 30 minutes until augmentation staff arrives. Therefore, when the compensation provided by established management expectations for immediate response as discussed in SE section 3.2.1 is considered along with the capability of the on-shift STA to provide core/thermal hydraulics expertise, the proposed change is acceptable.

3.2.9 Communicators and EOF supervisor, and NRC communicator - PPLs justification In the letter dated September 6, 2002, PPL proposed the following augmentation staff to fill the notification/communication function positions: two communicators within 60 minutes, another communicator within 90 minutes, and an EOF support supervisor within 90 minutes.

To compensate for extending the response times for these positions, PPL has added another communicator on shift in excess of the guidance in NUREG-0654.

NRC Staff Evaluation

Table B-1 of NUREG-0654 specifies the need for one communicator within 30 minutes and an additional communicator within 60 minutes. However, when the compensation provided by established management expectations for immediate response as discussed in SE section 3.2.1 is considered along with the additional on-shift communicator, the proposed change is acceptable.

3.3 Clarify engineering roles and responsibilities in the TSC and EOF - PPLs justification The SSES-1 and 2 Emergency Plan has been revised to require full engineering support in the TSC. The revision also clarifies the engineering function at the EOF as a support role and eliminates the Allentown General Office engineering as minimum staffing. The changes result in an Emergency Plan that is in full compliance with applicable regulations and is consistent with NUREG-0654. Engineering commitments in the current Emergency Plan require multiple engineering staffs at diverse locations. This creates the potential for confusion of roles and responsibilities and communication inefficiencies. The proposed changes result in a TSC

engineering function that is consistent with requirements of NUREG-0654 and will provide the full engineering support required. Discipline specific roles and responsibilities have been defined in Section 6 of the SSES-1 and 2 Emergency Plan for specific committed minimum staffing of this function. The skill set of personnel required in the TSC was modified and expanded from the more limited instrumentation and control discipline to the more general discipline of electrical engineer. The plan is now designed so that the TSC is responsible for overall engineering functions. The TSC will get support from the EOF and General Office as necessary. The engineering support supervisor is required for activation of the EOF to ensure proper communications and assessment of accident information at the EOF. This is consistent with the guidance of NUREG-0654. Additional augmentation in the EOF is anticipated and provisions are made for training and notification of assigned personnel. They are not, however, part of the minimum response commitment. The revised staffing tables have reduced the minimum engineering staff requirements for the EOF and general office and clearly specify requirements for the TSC.

NRC Staff Evaluation

In the letter dated September 6, 2002, as supplemented January 6 and 10, and February 7, 2003, PPL has proposed revisions to the text of Section 6 of the SSES-1 and 2 Emergency Plan and the content of Table 6.1 and Figures 6.2 and 6.3 (attached) to clarify the engineering roles and responsibilities in the TSC and EOF. The proposed changes do not reduce the effectiveness of the SSES-1 and 2 Emergency Plan and are acceptable.

3.4 Allow an emergency director to relieve the shift supervisor/shift manager as emergency director independent of the TSC - PPLs justification In the letter dated September 6, 2002, PPL stated that the proposed changes result in an Emergency Plan that is in full compliance with applicable regulations and is consistent with NUREG-0654. The past revisions of the Emergency Plan required the on-call emergency director to take over control of the emergency upon activation of the TSC. The on-call emergency director has the same responsibility to protect the health and safety of the public as the shift manager/supervisor. Both have a responsibility for mitigating actions. Changing the SSES-1 and 2 Emergency Plan to allow for a qualified emergency director to relieve the shift manager/supervisor as emergency director will allow the shift manager to return his focus to plant operations while the relieving emergency director maintains command and control of the overall emergency response. While the relieving emergency director will not have a full TSC staff until the TSC is fully activated, he will have the same staff that is currently available to the shift manager emergency director. In addition, relieving the shift manager provides additional mitigation capability. The relieving emergency director will have the on-shift staff available to perform dose assessment functions using the on-shift HP resources, sample analysis functions using the on-shift chemistry technician, engineering analysis using the shift technical advisor, and mitigating actions through the shift manager and the operating crew. Command and control of the emergency response will clearly be with the emergency director whether he is the shift manager or another qualified emergency director. Command and control of the operating crew remains the responsibility of the shift manager.

NRC Staff Evaluation

The proposed change to allow an emergency director to relieve the shift supervisor/shift manager as emergency director independent of the TSC is acceptable.

3.5 Clarify the minimum required ERF staffing - PPLs justification In the letter dated September 6, 2002, PPL states that the two tables associated with staffing levels and capability have been combined into one table that clearly defines the minimum staffing requirements. This new proposed Table 6.1 more closely matches NUREG-0654 guidance. The proposed changes result in the SSES-1 and 2 Emergency Plan being in full compliance with applicable regulations and is consistent with the guidance provided in NUREG-0654. The layout of the staffing tables in the SSES-1 and 2 Emergency Plan led to confusion of the current on-shift staffing and minimum requirements of ERFs. The SSES-1 and 2 Emergency Plan also included response positions that were not required by regulation resulting in inefficiencies in our emergency response. The augmented response to an event occurs within 60 minutes or 90 minutes. Past SSES-1 and 2 Emergency Plan terminology of 30-60 minutes and 60-90 minutes did not require or prevent an earlier response and was a source of confusion. Deleting the term "30" or "60" does not preclude an earlier activation.

The current version of Table 6.1 in the SSES-1 and 2 Emergency Plan provided "typical" staffing levels and required interpretation to provide information as to actual requirements.

Since the table provided limited value and was a major source of confusion as to commitments and staffing levels, the table was replaced with the proposed Table 6.1, which clearly defines minimum staffing positions. Also, in their supplemental letters dated January 6, January 10, and February 7, 2003, PPL provided proposed Figures 6.2 and 6.3 which show the TSC and EOF organizations, respectively.

NRC Staff Evaluation

The proposed revision to the SSES-1 and 2 Emergency Plan states that the TSC and OSC will now be fully operational within 60 minutes of an event classification. The proposed SSES-1 and 2 Emergency Plan states that staffing of the EOF occurs following an alert, a site area emergency, or a general emergency declaration. Also, the EOF is required to activate following a site area emergency, or a general emergency classification and take over management of the emergency from the TSC within 90 minutes of the site area emergency or higher classification.

In addition, activation of the EOF requires the minimum staff as identified in Figure 6.3 (attached).

NUREG-0737, Supplement 1, Section 8.2.1.j, states in part, that the TSC will "...be fully operational within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after activation." PPLs proposed changes to the SSES-1 and 2 Emergency Plan meet this guidance and the standard in 10 CFR 50.47(b)(2).

NUREG-0696, Section 4.3, states in part, that the EOF should be fully operational within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after activation. PPLs proposed changes to Table 6.1 and Figure 6.3 exceed this guidance.

However, PPL has proposed SSES-1 and 2 Emergency Plan changes, which are discussed in SE sections 3.2 and 3.3, that provide sufficient justification to extend the EOF "fully operational time" to 90 minutes and meet the standard in 10 CFR 50.47(b)(2).

3.6 Emergency action level changes- PPLs justification PPL proposes changes to the emergency action levels associated with radiological effluents.

PPL stated that the changes made at the unusual event and alert levels were made to permit

the deletion of the iodine and particulate count rate detectors and readout. The basis for removal of the detectors is provided in the PPL assessment of Super Particulate Iodine Noble Gas Accident Monitoring Limitations which notes that there are several short-lived noble gas nuclides that will interfere with the iodine channel, either directly or as a result of their particulate decay products accumulating in the iodine cartridge. The changes to the unusual event and alert noble gas vent release limits are based on a PPL calculation. The TRM whole-body exposure limit of 500 mrem/yr is used as a basis from which the limiting release rate is back calculated to provide the unusual event and alert level thresholds.

PPL further stated the changes to the EAL at the site area and general emergency levels were made to eliminate confusion resulting from poor wording of the existing EAL.

NRC Staff Evaluation

PPLs overall EAL scheme is based on the example initiating conditions (ICs) presented in NUREG-0654, Appendix 1, Emergency Action Level Guidelines for Nuclear Power Plants.

The unusual event IC-2 states Radiological effluent technical specification limits exceeded.

The alert IC-15 states Radiological effluents greater than 10 times technical specification instantaneous limits (an instantaneous rate which, if continued over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, would result in about 1 mr at the site boundary under average meteorological conditions). PPL has provided an alternative to the NUREG-0654 methodology scheme for the unusual event and alert levels.

This alternative has been reviewed and is consistent with the guidance provided in NUMARC-007, Rev. 2, Methodology for Development of Emergency Action Levels, dated January 1992. The changes made to the site area and general emergency action level are editorial in nature.

Appendix E of 10 CFR Part 50, states: These emergency action levels will be discussed and agreed on by the applicant and State and local governmental authorities and approved by NRC. In response to a request for additional information, PPL indicated these agreements had been reviewed and agreed upon on September 19, 2002. This satisfies the requirement of Appendix E.

4.0 CONCLUSION

The NRC staff has determined that PPL's proposed SSES-1 and 2 Emergency Plan changes in its application dated September 6, 2002, as supplemented by letters dated January 6, January 10, and February 7, 2003, are acceptable. The NRC staff also finds that the SSES-1 and 2 Emergency Plan changes meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E of 10 CFR Part 50. Therefore, the Commission concludes, 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) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed emergency plan changes will not be inimical to the common defense and security or to the health and safety of the public.

In addition, based on the review of the proposed change to the EAL classification scheme for SSES-1 and 2, the staff concludes that the revised EAL, including the deviations discussed in this review, are consistent with the guidance in NUREG-0654 or NUMARC-007 where

appropriate, and therefore, continue to meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.

Attachments: SSES-1 and 2 Emergency Plan Table 6.1, Figure 6.2, and Figure 6.3 Principal Contributors: R. Moody T. Blount Date: March 24, 2003