PLA-6939, Response to Request for Additional Information on Exemption Request from Biennial Emergency Preparedness Exercise Requirements of 10CFR50, App E, Section IV.F.2.b
| ML123350107 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/29/2012 |
| From: | Helsel J Susquehanna |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PLA-6939 | |
| Download: ML123350107 (7) | |
Text
Jeffrey M. Helsel Plant Manager U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 PPL Susquehanna, LLC 769 Salem Boulevard Berwick, P A 18603 Tel. 570.542.3510 Fax 570.542.1504 jmhelsel @pplweb.com SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: EXEMPTION REQUEST FROM THE BIENNIAL EMERGENCY PREPAREDNESS EXERCISE REQUIREMENTS OF 10 CFR 50, APPENDIX E, SECTION IV.F.2.b PLA-6939 Docket Nos. 50-387 and 50-388
References:
- 1) Letter, J. Whited (NRC) toT. Rausch (PPL), "Susquehanna Steam Electric Station, Units 1 and 2 - Request for Addition Information Re: Exemption Request from the Biennial Emergency Preparedness Exercise Requirements of 10 CFR 50, Appendix E, Section N.F.2.b (TAC NOS. ME9845 and ME9846)," dated November 21, 2012.
- 2) PLA-6922, T. Rausch (PPL) to Document Control Desk (NRC), "Exemption Request from the Biennial Emergency Preparedness Exercise Requirements of 10 CFR, Appendix E,Section IV.F.2.b," dated October 25, 2012. (ML12300A108)
- 3) NRC Regulatory Issue Summary 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements," dated February 24, 2006.
PPL Susquehanna, LLC (PPL) requested in Reference 2, a one-time exemption from the requirements of 10 CPR 50, Appendix E,Section IV.F.2.b to reschedule the evaluation of the onsite elements of the Susquehanna Steam Electric Station's (SSES's) biennial Emergency Preparedness exercise from October 23, 2012 to February 26, 2013. After review of this request, the NRC identified the need for PPL to provide additional information in a November 21, 2012letter to PPL (Reference 1). The Attachment to this letter provides PPL' s response to the request for additional information.
If you have any questions regarding this letter, please contact Mr. John L. Tripoli, Manager, Nuclear Regulatory Affairs, at (570) 542-3100.
This letter contains no new regulatory commitments.
r\\
-et/;l~ ~~
J. M. Helsel Attachment Copy: Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. J. Whited, NRC Project Manager Mr. L. Winker, P A DEP/BRP Administrator, NRC Region I Document Control Desk PLA-6939
Attachment to PLA-6939 Response to Request for Additional Information Re: Exemption Request from the Biennial Emergency Preparedness Exercise Requirements of 10 CFR 50, Appendix E, Section IV.F.2.b
Attachment to PLA-6939 Page 1 of 4 Response to Request for Additional Information Re: Exemption Request from the Biennial Emergency Preparedness Exercise Requirements of 10 CFR 50, Appendix E, Section IV.F.2.b NRC RAil:
Section IV.F.2.b of 10 CFR Part 50, Appendix E requires licensees at each site to conduct an exercise of onsite emergency plans biennially. Please specifically discuss why the onsite portion of the biennial exercise could not be conducted prior to the end of the year (e.g., exercise scenario is compromised and a new scenario will need to be developed and submitted to the NRC, simulator unavailability to support development and validation of changes to scenario due to required Operator examinations through the end of the year, etc.).
Because the decision was made to proceed with the offsite portion of the Biennial Emergency Preparedness Exercise on October 23, 2012, the approved scenario developed for the NRC Evaluation was used to satisfy the needs of FEMA in evaluating the response of the offsite agencies. This compromised the security of the scenario and requires development of a new scenario for the onsite evaluated exercise.
Development of a new scenario requires a significant amount of time and resources. Six weeks are required to establish the type of exercise, input the information, including the radiological response, and validate the scenario prior to submittal to the NRC for review.
The NRC requires 60 days to review the scenario which would result in performance of the exercise in late February 2013. Expedited development and review of a new scenario is not possible due to the limited resources caused by the Unit 1 and Unit 2 unplanned outages, and unavailability of the simulator which also supports Licensed Operator Requalification, Initial Licensed Operator training, and other activities to meet the needs of the Operations organization.
Below is the proposed time line for the February 26, 2013 NRC-evaluated Emergency Preparedness (EP) Exercise.
10/29/12-11/30/12 11/30/12 Develop preliminary scenario Submit preliminary scenario to:
Simulator instructor for simulator scenario development Steve Barr (NRC Inspector) for comment Operations Supervisor and EP staff for review and comment
12/14/12 1/18/13 2/26/13 NRCRAI2:
Attachment to PLA-6939 Page 2 of4
- 1) Validate scenario with operating crew (tentative)
- 2) Submit package to NRC (60-day requirement)
Finalize EP exercise data package NRC Evaluated Exercise PPL stated that the offsite portion of the biennial exercise was successfully performed on October 23, 2012. Please describe what licensee support contributed to this exercise (e.g., a validated exercise scenario with expected EAL classifications and protective action recommendations was provided to offsite authorities, what licensee ERO positions were simulated, what licensee support was provided at the EOC, etc.).
PPL provided the off site notifications of the scenario events to the Risk Counties and the Pennsylvania State Emergency Management Agencies, including the State Bureau of Radiological Protection, during the conduct of the October 23, 2012 exercise.
All PPL onsite positions that would provide the communications to I from offsite agencies regarding EAL classifications and Protective Action Recommendations were staffed by control cells comprised of Emergency Planning and Regulatory Affairs staff.
As noted in RAI 1 response above, the approved scenario was run on the simulator which required one simulator instructor to participate. In addition, one Recovery Manager who was not assigned an outage duty the day of the drill also participated as a control cell, specifically to address the communications with the Senior State Official. The control cells were all staffed at our EOF and no interaction was planned or occurred at the site during performance of the offsite portion of the evaluated exercise. This was purposely planned to assure that no distraction would be introduced onsite during the discovery phase of the Unit 1 turbine outage. County Liaisons were also assigned to Luzerne and Columbia County EOCs to participate in the exercise.
Several out of sequence activities were evaluated by FEMA during the evaluated exercise week. PPL support for these activities was also provided by Emergency Planning and Regulatory Affairs staff.
The FEMA public briefing was held on October 26, 2012. The preliminary results were noted to be very good and identified no concerns with the ability to protect the health and safety of the public. (Note: these results are subject to change until issuance of the final report by FEMA.)
NRCRAI3:
Attachment to PLA-6939 Page 3 of4 Page 2 of the exemption request provides a discussion on a risk perspective. Please describe what increased risk to public health and safety is incurred by performing the biennial exercise in the remaining CY 2012 as opposed to the risk to public health and safety of the exercise if rescheduled to February 2013.
The increase in risk as described in Page 2 of our original request was related to the performance of the onsite portion of the exercise during the outage. Attempting to conduct the exercise in parallel with the outage would divert outage resources and would require a higher level of coordination between the two activities to prevent human performance errors. Our Operations Support Center (OSC) also serves as an Outage Control Center (OCC). This facility dispatches drill work teams and serves as a hub for control of outage activities. The plant communication systems are also common for both outage activities and the exercise. Although measures would be taken to segregate these activities as much as possible, there exists a higher potential for communication and coordination errors (i.e., increased risk to the public health and safety). Since the security of the original exercise was compromised during the October 23, 2012 offsite EP exercise, a new scenario is being developed. The challenge in developing and implementing a new scenario in the remaining CY2012 is discussed in PPL's response to RAI 1 above.
NRCRAI4:
Please provide additional information for Tables 1 and 3 to include further discussion relative to whether these drills tested the integrated capability and major functions of the emergency plan. Additionally, what offsite agencies participated in the drills provided in Table 1?
The full-scale drills referenced in Table 1 of Reference 2 are conducted based on the criteria outline in 10 CFR 50, Appendix E, and other regulatory guidance. The evaluation criteria are used to ensure that individual, facility, and inter-facility performance meets the required standards. During full-scale drills, offsite agencies normally participate to the extent necessary to ensure that communications between PPL and the agencies are accurately received. See revised Table 1 below.
Full Scale Drill Dates 6/28/2011 8/23/2011 9/13/2011 11/01/2011 2/07/2012 8/28/2012 11/13/2012 Attachment to PLA-6939 Page 4 of 4 Table 1-Completed Full Scale Drills 2010-2012 SSES Participation State and Local Participation All Station Emergency Response State and Local Government Facilities and Simulator Agency communications All Station Emergency Response State and Local Government Facilities (except TSC), Alternate Agency communications OSC, Alternate TSC, and Simulator All Station Emergency Response State and Local Government Facilities and Simulator Agency communications All Station Emergency Response State and Local Government Facilities and Simulator Agency communications All Station Emergency Response State and Local Government Facilities and Simulator Agency communications All Station Emergency Response State and Local Government Facilities and Simulator Agency communications All Station Emergency Response State and Local Government Facilities (except TSC), Alternate Agency communications OSC, Alternate TSC, and Simulator The drills listed in Table 3 of Reference 2 only tested the emergency response organization to ensure participants maintain the proper level of readiness to perform their responsible duties. For the drills listed in Table 3 of Reference 2, the offsite agencies do not participate. See revised Table 3 below.
Table 3 -Practice Drills 2010-2012 Practice Drill SSES Participation State Dates Participation 11/2/2010 TSC, OSC, EOF, JIC None 1/11/2011 TSC, OSC, EOF, JIC None 6/16/2011 TSC, OSC, EOF, JIC None 8/09/2011 Alternate OSC, Alternate TSC, OSC, EOF, JIC None 8/30/2011 TSC, OSC, EOF, JIC None 10/18/2011 TSC, OSC, EOF, JIC None 1/17/2012 TSC, OSC, EOF, JIC None 7/13/2012 TSC, OSC, EOF, JIC None 7/20/2012 TSC, OSC, EOF, JIC None 7/27/2012 TSC, OSC, EOF, JIC None 8/03/2012 TSC, OSC, EOF, JIC None 8/14/2012 TSC, OSC, EOF, JIC None 10/9/2012 TSC, OSC, EOF, JIC None