ML12076A120
| ML12076A120 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Clinton, Quad Cities, LaSalle  |
| Issue date: | 03/13/2012 |
| From: | James Anderson Office of Nuclear Security and Incident Response |
| To: | Quinn V US Dept of Homeland Security, Federal Emergency Management Agency |
| Joseph Anderson | |
| Shared Package | |
| ML12069A333 | List: |
| References | |
| Download: ML12076A120 (2) | |
Text
1 Anderson, Joseph From:
Anderson, Joseph Sent:
Tuesday, March 13, 2012 2:01 PM To:
Quinn, Vanessa Cc:
Greten, Timothy; King, William; Skokowski, Richard; Jickling, Robert; Beavers, James; Barker, Allan; Logaras, Harral; Norris, Michael; Wiebe, Joel
Subject:
Deferral of Ingestion Pathway Exercise for the State of Illinois Attachments:
ML12069A3332.pdf Ms. Quinn:
The purpose of this email is to: (1) document Federal Emergency Management Agency (FEMA) Region Vs request to reschedule the Ingestion Pathway Exercise (IPX) for the State of Illinois, and (2) FEMA Region Vs evaluation of the impact of deferring this request outside the current exercise cycle timeframe. The email also serves to document FEMAs authority for determining the acceptability of this deferral.
Enclosed is a letter from Exelon Nuclear dated March 9, 2012, which serves to document Exelons discussions with the NRC, FEMA, and the Illinois Emergency Management Agency (IEMA) regarding FEMA Region Vs request to reschedule the IPX for the State of Illinois associated with Exelons Braidwood, Byron, Clinton, Dresden, LaSalle and Quad Cities Nuclear Power Stations. This letter has been entered into the NRCs Agency Documents Access and Management System (ADAMS) as publicly available under Accession No.:
to this letter is correspondence dated January 25, 2012, from Mr. William E. King, FEMA Region V Regional Assistance Committee (RAC) Chair, to Mr. David L. Smith, IEMA Disaster Assistance and Preparedness Chief. This correspondence serves to document discussions held at the November 2010 Radiological Emergency Preparedness (REP) Scheduling Conference between IEMA, Exelon, and FEMA Region V that would move the IPX for the State of Illinois from the LaSalle Station exercise in August 2012 to the Clinton Station exercise scheduled for March 26-27, 2013. The rescheduling of the IPX was made by FEMA Region V upon recognition that three offsite IPXs were scheduled to be conducted during a three month period, which would be unmanageable for FEMA evaluation, and would surely reduce the opportunity for Federal participation. The correspondence identifies that this change may also require coordination between the Utility [licensee] in order to gain approval from the NRC to perform the IPX for the State of Illinois beyond the current six year cycle deadline.
to this letter is correspondence dated January 25, 2012, from Mr. William E. Conway, IEMA REP Program Manager, to Mr. Gerald DeYoung (Exelon Nuclear) indicating IEMAs review of FEMA Region Vs request to change the State of Illinois IPX from August 2012 to March 2013. In the response, IEMA indicates their full support for Exelons request to the NRC for approval in changing the exercise date. In addition, IEMA states The postponement of this exercise for a few months beyond the normal six year cycle will neither diminish the State of Illinois level of preparedness nor put at risk the health and safety of the general public.
The Emergency Preparedness (EP) Rule, published on November 23, 2011, and effective on December 23, 2011, states the following under Section IV.F.2.d to Appendix E of Title 10 Part 50 of the Code of Federal Regulations (10 CFR 50): Each State with responsibility for nuclear power reactor emergency preparedness should fully participate in the ingestion pathway portion of exercises at least once every exercise cycle. In States with more than one nuclear power reactor plume exposure pathway [emergency planning zone] EPZ, the State should rotate this participation from site to site. This new EP Rule revised the previous exercise cycle from six to eight years, with the first eight-year exercise cycle for a site beginning in the calendar year in which the first hostile action exercise is conducted. Since the State of Illinois has not yet participated fully nor is scheduled in calendar year 2012 to participate in a hostile action exercise under the new EP Rule, then the existing six-year exercise cycle remains in effect for the State of Illinois. As such, deferral of the IPX for the State of Illinois from August 2012 to March 2013 would exceed the six-year exercise cycle.
2 Per discussions with the NRCs Office of General Counsel (OGC) and members of our Inspection and Regulatory Improvements Branch, it was determined that as written Appendix E to 10 CFR 50 merely states that Each State with responsibility for nuclear power reactor emergency preparedness should fully participate in the ingestion pathway portion of exercises In addition, the responsibility for IPX participation rests with the respective State, and as such, any deferment of this demonstration is subject to FEMAs determination regarding continued reasonable assurance. In FEMA Region Vs letter dated January 25, 2012, Mr. King states:
We recognize that this would move the State of Illinois outside their current six-year timeframe for conducting an IPX. We considered past exercise performance, no outstanding issues, and a relatively short (four month) extension, in our decision to extend the performance of offsite IPX objectives to the Clinton exercise.
As such, based on FEMA Region Vs correspondence dated January 25, 2012, no action on the part of the NRC is required.
Please contact either myself or Mike Norris (301-415-4098) if you have any questions or would like to discuss this issue further.
Joseph D. Anderson, Chief Operating Reactor Licensing and Outreach Branch Division of Preparedness and Response Office of Nuclear Security & Incident Response U.S. Nuclear Regulatory Commission Mail Stop: T-3B46M Washington, DC 20555-0001 Telephone: 301.415.4114 Blackberry: 202.236.6417 E-mail: joseph.anderson@nrc.gov This message is for the designated recipient only and may contain privileged or confidential information. If you have received it in error, please notify the sender immediately and delete the original. Any other use of this e-mail by you is prohibited.