RA-13-077, Company License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel

Company License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel

ML13304B168
Person / Time
Site:	Peach Bottom, Oyster Creek, Limerick, Crane
Issue date:	10/30/2013
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, NRC/FSME, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
RA-13-077, TMI-13-108
Download: ML13304B168 (22)

Text

RA-13-077 TMI-13-108 10 CFR 50.90 10 CFR 50.54(q)

October 30, 2013 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001

Subject:

Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353 and 72-65 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Peach Bottom Atomic Power Station, Units 1, 2 and 3 Facility Operating [Possession-Only) License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277. 50-278 and 72-29 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only License No. DPR-73 NRC Docket No. 50-320 License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit, II Exelon Generation Company, LLC (Exelon) requests amendments to the licenses for the facilities listed above.

Specifically, the proposed change would revise the Emergency Response Organization (ERO) requalification training frequency from every 12 months (plus a 25°/o grace period -

three months) to annually as defined in the Exelon Nuclear Standardized Radiological Emergency Plan for the affected facilities. The Emergency Plan is described in each facilitis Updated Final Safety Analysis Report (UFSAR). In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans," Exelon requests U.S.

Nuclear Regulatory Commission (NRC) approval of the proposed change for the Exelon

...,....,,,....,..,., Regulatory

......................... Amendment 1-Ct:::l\\./I~A Emergency Plan Requalification Training Frequency 2013 Nuclear Radiological Emergency Plan Annexes for Limerick Generating Station, Oyster Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station. The proposed change is consistent with the guidance in NRC Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011.

The proposed change has been reviewed by the Plant Operations Review Committees at each station and has been approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program. provides an evaluation of the proposed change, including a detailed description, technical and regulatory evaluations including a no significant hazards consideration, and an environmental consideration. Attachments 2 through 5 provide mark-ups of the existing Emergency Plan pages showing the proposed change to each facility*s Emergency Plan.

There are no regulatory commitments contained in this submittal.

Exelon requests approval of the proposed license amendments by October 30, 2014. Once approved, Exelon is requesting that the amendments be implemented within 90 days.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania and the State of New Jersey of this application for license amendments by transmitting a copy of this letter and its supporting attachments to the designated state officials.

Should you have any questions regarding this submittal, please contact Richard Gropp at (61 0) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of October 2013.

Respectfully, James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Emergency Plan Mark-ups, Limerick Generating Station, Units 1 and 2

3. Emergency Plan Mark-ups, Oyster Creek Nuclear Generating Station

4. Emergency Plan Mark-ups, Peach Bottom Atomic Power Station, Units 1, 2, and 3

5. Emergency Plan Mark-ups, Three Mile Island Nuclear Station, Units 1 and 2

U.S. Nuclear Regulatory Commission Amendment Request Revise Emergency Plan Requalification Training Frequency October 30, 2013 Page 3 cc:

Regional Administrator-NRC Region I NRC Senior Resident Inspector-Limerick Generating Station NRC Senior Resident Inspector-Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector-Peach Bottom Atomic Power Station NRC Senior Resident Inspector-Three Mile Island Nuclear Station NRC Project Manager, NRR-Exelon Fleet Project Manager, NRR Limerick Generating Station Project Manager, NRR-Oyster Creek Nuclear Generating Station Project Manager, NRR-Peach Bottom Atomic Power Station Project Manager, NRR-Three Mile Island Nuclear Station Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ S. T. Gray, State of Maryland R. R. Janati, Commonwealth of Pennsylvania

ATTACHMENT 1 License Amendment Request EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization for Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

ATTACHMENT 1 License Amendment Request Revise Emergency Plan Requalification Training Frequency for Emergency Organization Page 1 of 10 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, ~~Application for amendment of license, construction permit, or early site permit, II Exelon Generation Company, LLC (Exelon) requests amendments to the licenses for the plants listed below:

NPF-39 and NPF-85 for Limerick Generating Station, Unit 1 and 2, respectively DPR-16 for Oyster Creek Nuclear Generating Station DPR-12, DPR-44, and DPR-56 for Peach Bottom Atomic Power Station, Units 1, 2, and 3, respectively DPR-50 and DPR-73 for Three Mile Island Nuclear Station, Units 1 and 2, respectively The proposed change would revise the Emergency Response Organization (ERO) training requalification frequency from once every 12 months (plus a 25°/o grace period - three months) to annually as defined in the Exelon Nuclear Standardized Radiological Emergency Plans for the affected facilities.

The Emergency Plan is described in each facility's Updated Final Safety Analysis Report (UFSAR). In accordance with 10 CFR 50.54, "Conditions of licenses, II paragraph (q),

"Emergency plans," Exelon requests U.S. Nuclear Regulatory Commission (NRC) approval of the proposed change to the Exelon Nuclear Radiological Emergency Plan Annexes for Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station. The proposed change is consistent with the guidance in NRC Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes, II dated April 19, 2011.

2.0 DETAILED DESCRIPTION Planning Standard 10 CFR 50.47(b)(15) specifies that Radiological Emergency Response Organization (ERO) training is provided to those who may be called on to assist in an emergency. This is further expanded in regulatory guidance provided in NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, "which specifies that organizations shall establish specialized initial and periodic retraining programs for those who may be called on to assist in an emergency.

The Exelon Nuclear Radiological Emergency Plan Annexes for the Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station, include the following frequency requirement for ERO training in the respective station's Emergency Plan Annex (Section 2.3):

2.3 Emergency Response Organization (ERO) Training Training is conducted in accordance with Section 0.5 of the Exelon Nuclear Standardized Radiological Emergency Plan per TQ-AA-113, "ERO Training

ATTACHMENT 1 Amendment Request 1"""\\f..l\\/l........ Emergency Plan Requalification Training for Emergency Response Organization 10 and Qualification." Retraining is performed on an annual basis, which is defined as every 12 months + 3 months (25% grace period).

In contrast to this requirement stated above, the Exelon Nuclear Standardized Radiological Emergency Plan provides the following guidance for ERO training.

Section 0.4, Emergency Response Organization Training Program Exelon Nuclear ERO personnel who are responsible for implementing this plan receive specialized training. The training program for emergency response personnel is developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities as defined in this document.

On-Shift emergency response personnel perform emergency response activities as an extension of their normal duties and are trained annually as part of their duty specific training. Additional Emergency Preparedness information is provided as part of the Station Nuclear General Employee Training.

New ERO personnel receive an initial overview course that familiarizes them with the E-Pian by providing basic information in the following areas as well as specific information as delineated in the sections below:

Planning Basis Emergency Classifications Emergency Response Organization and Responsibilities Call-out of Emergency Organization Emergency Response Facilities Communications Protocol/Emergency Public Information Offsite Organizations Emergency response personnel in the following categories receive knowledge and/or performance based training initially and retraining thereafter on an annual basis as defined within Appendix 4 or applicable Station Annex:...

The ERO personnel receiving the knowledge and/or performance based training include:

Directors, Managers and Coordinators within the station and corporate ERO Personnel Responsible for Accident Assessment Radiological Monitoring Teams and Radiological Analysis Personnel Police, Security, and Fire Fighting Personnel Repair and Damage Control Teams First Aid and Rescue Personnel Local Support Service Personnel Medical Support Personnel Public Information Personnel Communications Personnel

ATIACHMENT 1 Amendment Request Revise Emergency Plan Requalification Training Frequency for Emergency Response Organization 3

10 The term "Annual" is defined in the Exelon Nuclear Standardized Radiological Emergency Plan Glossary as:

Frequency of occurrence equal to once per calendar year, January 1 to December

31.

Under the Exelon Emergency Preparedness Program, the Exelon Nuclear Standardized Radiological Emergency Plan is common between all of Exelon's ten (10) nuclear stations.

Site specific guidance relating to Emergency Plan requirements is contained in each Station's Emergency Plan Annex. Together, the Standard Plan and the Station Annex make up the site's Emergency Plan. The Emergency Plan is arranged such that requirements in the Annex take precedence when contradictory statements exist. Section A, "Purpose, II of the Standard Plan provides the following explanation:

"... The Station Annex becomes a part of the plan and is subject to the same review and audit requirements as the plan. In the areas where a Station Annex deviates from the general requirements of the E-Pian, the Station Annex shall serve as the controlling document......

Regarding the ERO requalification training frequency, Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station have historically implemented an ERO requalification training frequency which is different than that stipulated in the Exelon Standard Plan and utilized by the six other Exelon stations (Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, and Quad Cities Nuclear Power Station). For the Exelon Mid-Atlantic stations (Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station), the required frequency for ERO requalification training is established at once every 12 months and permits a three-month grace period.

The other Exelon stations located in the Midwest (noted above) follow the guidance established in the Standard Plan, which requires annual ERO requalification training to be performed within each calendar year. The difference in the training frequency can be attributed to the difference in Emergency Plan commitments that existed at the time when PECO and UN I COM merged to form Exelon. It was recognized at the time that the two separate companies had different requirements/commitments regarding ERO requalification training frequency.

The proposed change in the ERO requalification training frequency for the four affected facilities would result in a change to each station*s Emergency Plan Station Annex. Section 2.3, "Emergency Response Organization (ERO) Training, II in each station*s Annex provides an identical description regarding the ERO requalification training frequency. Exelon proposes to modify the discussion in Section 2.3 to delete the reference to "... every 12 months + 3 months (25% grace period), II as described below.

ATTACHMENT 1

• "0 '"'~ 0 Amendment 1-Ct:::l\\/I<;;!P Emergency Plan Requalification Training for Emergency Organization 10 2.3 Emergency Response Organization (ERO) Training Training is conducted in accordance with Section 0.5 of the Exelon Nuclear Standardized Radiological Emergency Plan per TQ-AA-113, UERO Training and Qualification." Retraining is performed on an annual basis, y,ehich is defined as e~ery 12 months : 3 months (259f. grace period).

Following the deletion, the description currently in the Standard Plan (excerpt below) would then be the governing requirement regarding the ERO requalification training frequency.

Section 0: Emergency Response Training General, Initial, and Annual Training Program Maintenance

b. Initial and Requalification ERO Training: The proficiency of emergency response personnel (as defined in 10 CFR 50 Appendix E) is ensured by the following means:

Initial training and annual retraining on applicable generic and site-specific portions of the E-Pian and the corresponding implementing procedures.

Individuals not demonstrating the required level of knowledge in initial or retraining classes receive additional training on the areas requiring improvement. Annual retraining is conducted on a calendar year basis, or as indicated in the Station Annex.

The following procedures are the Standard Emergency Plan and site-specific Annexes for the affected facilities, which make up the Emergency Plan for the stations supported by this License Amendment Request. Markups of the proposed Emergency Plan page changes are provided in Attachments 2 through 5. There are no changes proposed to the Standard Emergency Plan.

EP-AA-1000, "Exelon Nuclear Standardized Radiological Emergency Plan" EP-AA-1007, "Exelon Nuclear Radiological Emergency Plan Annex for the Peach Bottom Atomic Power Station" EP-AA-1 008, "Exelon Nuclear Radiological Emergency Plan Annex for the Limerick Generating Station" EP-AA-1 009, "Exelon Nuclear Radiological Emergency Plan Annex for the Three Mile Island (TMI) Station

EP-AA-1 01 0, "Exelon Nuclear Radiological Emergency Plan Annex for Oyster Creek Station"

3.0 TECHNICAL EVALUATION

Exelon proposes to revise the Emergency Plan Station Annexes for Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station,

ATIACHMENT 1 Amendment Request 1"-(;:::l\\/lc:;:;:::l Emergency Plan Requalification Training for Emergency Response Organization 10 and Three Mile Island Nuclear Station to establish an ~~annual" ERO requalification training frequency and to align the training frequency across the Exelon fleet at all ten (1 0) sites.

This constitutes a minor change which will allow application of common procedural guidance and administrative tracking tools throughout the company.

Exelon's Mid-Atlantic stations (Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station) have historically defined the annual training requirement to be 12 months plus a three-month grace period. The use of a grace period is not used systematically or repeatedly to extend training intervals. As such, the grace period would not be additive, and as applied to the EP program, performance of ERO requalification training would be performed each year at nominally a one-year interval.

From a business needs perspective, there is a benefit for Exelon to have all ten (1 0) stations perform ERO training under the same requirements. Exelon utilizes common procedures and programs to manage the Emergency Preparedness training program and having all of its stations under the same program would provide efficiency and simplicity in program administration.

The current practice of utilizing a 25°/o grace period for annual ERO training introduces some hardships and unintended consequences which can complicate the scheduling of training. For example, station maintenance outages or other major station events may require the ERO requalification cycle to be rescheduled (entirely or partially) either earlier or later within the year. If a portion of the ERO has their training cycle accelerated, the subsequent year's training cycle would still need to be performed within the 12 months plus the three-month period. Considering some stations utilize five ERO teams and train over several weeks or months, this may introduce individual tracking and scheduling complications, particularly when individuals change ERO teams. Qualifications are required to be more closely monitored and the need for emergent or individual training is minimized with this proposed change. The monitoring of individual training becomes simplified with the.. annual.. requalification frequency defined in the Standard Plan.

When the two frequencies for training requalification are compared over a period of several years, both methods result in the same number of training opportunities for the ERO personnel, with the understanding that the allowed grace periods are not used to extend training intervals. Additionally, the annual frequency as defined in the Standard Plan is consistent with the time constraints of other EP program requirements. For example, Emergency Plan reviews, Emergency Action Level (EAL) reviews, distribution of Emergency Preparedness public materials, offsite response organization Letters of Agreements, and Alert and Notification System (ANS) preventive maintenance are performed on an.. annual" basis as defined in the Standard Plan.

One impact of the change would be that it would be possible to schedule requalification training in January of one year and December of the following year. Under these circumstances, an individual could go 23 months without requalification training. Under the current training program for the Mid-Atlantic plants (Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile

ATTACHMENT 1

,,.......... <f".... Amendment Revise Emergency Plan Requalification Training Frequency for Emergency Organization Page 6 of 10 Island Generating Station), the maximum training interval would 15 months (i.e., 12 months plus a 3-month period). While this may true, experience under the calendar year program for the other stations (Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, and Quad Cities Nuclear Power Station), shows there is no advantage to such scheduling.

The Exelon stations nominally schedule ERO training at the same time each year with few exceptions. ERO performance is consistent under both requalification tracking methods within Exelon, and as noted, over a period of time, the number of training opportunities is equivalent Over a ten-year interval, ERO requalification training under the current program would be provided ten (1 0) times (with the acknowledgement that the tenth year may utilize the allowed three-month grace period). This is consistent with the "annual" requalification requirements as currently stated in the Standard Emergency Plan as applied to the Midwest Exelon stations. The "annual" training, defined as once-per-calendar year (January 1 to December 31 ), would also occur ten (1 0) times over a period of ten years.

The revision to the training frequency would have no impact to NRC Performance Indicators (Pis). The NRC ERO Drill Participation performance indicator tracks the participation of ERO members assigned to fill key positions in performance enhancing experiences and through linkage to the Drill and Exercise Performance (DEP) indicator ensures that the risk significant aspects of classification, notification, and Protective Action Recommendation (PAR) development are evaluated and included in the PI process. This indicator measures the percentage of ERO members assigned to fill key positions who have participated recently in performance-enhancing experiences such as drills, exercises, or in an actual event during the previous eight quarters, as measured on the last calendar day of the quarter.

The proposed revision to the annual training frequency is unrelated to drill participation requirements for the indicator. Although a drill participation requirement currently exists as a separate element of the ERO qualification process, it does not impact the objective for key ERO members to have a performance-enhancing experience every eight quarters.

The proposed change in the ERO requalification training frequency for the affected Exelon Mid-Atlantic sites would result in consistency with other Emergency Plan program requirements, as well as the Exelon Midwest sites* ERO requalification training requirements. The flexibility to schedule training within the calendar year allows the Emergency Preparedness organizations to schedule around planned and emergent outages, operations training cycles, and other emergent station priorities.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.

ATTACHMENT 1

'""""""'"'""' Amendment H,::;:l\\/1~,::;:1 Emergency Plan Requalification Training Frequency for Emergency Response Organization 7 of 10

"""~'*~,.,~ in 10 CFR 50.54(q) provide direction to licensees seeking to revise their 1-rnornon,.. \\J Plan. The requirements related to nuclear power plant Emergency Plans are specified in the standards in 10 CFR 50.47, "Emergency plans," and the requirements of 10 CFR Appendix "Emergency Planning and Preparedness for Production and Utilization Facilities."

Planning Standard 10 CFR 50.47(b)(15) states that: "Radiological emergency response training is provided to those who may be called on to assist in an emergency." This is further discussed in NUREG-0654, Section 11.0, "Radiological Emergency Response Training, II which states that: "Each organization shall assure the training of appropriate individuals." More specifically, step 5 states: "Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities. " The proposed change to the affected sites' Emergency Plans reflects a change in frequency in how ERO requalification training is implemented at those affected Exelon facilities. Exelon has determined that the proposed change does not require any exemptions or relief from regulatory requirements and does not affect conformance with any 10 CFR 50, Appendix A,

.. General Design Criteria for Nuclear Power Plants," (GDC) criteria differently than that described in the Updated Final Safety Analysis Reports (UFSARs) for each affected facility.

4.2 Precedent There is current precedent within the Exelon fleet supporting the proposed change. The ERO requalification training requirements specified in the Emergency Plans for Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, and Quad Cities Nuclear Power Station include provisions for ~~annual" training as defined to be once per calendar year.

In addition, plants from Constellation and Entergy institute ERO personnel requalification training on an.. annual" basis (i.e., once per calendar year):

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to the following licenses:

NPF-39 and NPF Limerick Generating Station, Units 1 and 2, respectively DPR Oyster Creek Nuclear Generating Station DPR-12, DPR-44, and DPR Peach Bottom Atomic Power Station, Units 1, 2 and 3, respectively DPR-50 and DPR Three Mile Island Nuclear Station, Units 1 and 2, respectively Specifically, the proposed change would revise the Emergency Response Organization (ERO) requalification training frequency from every 12 months (plus a 25°/o grace period - 3 months) to annually as defined in the Exelon Nuclear Standardized Radiological Emergency Plan. The Emergency Plan is described in each station's Updated Final Safety Analysis Report (UFSAR). In accordance with 10 CFR 50.54, "Conditions of licenses,"

ATIACHMENT 1

'"0 '"~ 0 Amendment Request Revise Emergency Plan Requalification Training Frequency for Emergency Response Organization 8 of 10 paragraph (q), "Emergency plans," Exelon requests NRC approval of the proposed change to the Exelon Nuclear Radiological Emergency Plan Annexes for Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station. The proposed change is consistent with the guidance in NRC Regulatory Issue Summary 2005-02, Revision 1, ~~clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011.

The proposed change has been reviewed considering the applicable requirements of 1 0 CFR 50.47, 10 CFR 50, Appendix and other applicable NRC documents. Exelon has evaluated the proposed change to the affected sites* Emergency Plans and determined that the change does not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards, set forth in 10 CFR 50.92,

Issuance of amendment," is provided below.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change does not increase the probability or consequences of an accident. The proposed change does not involve the modification of any plant equipment or affect plant operation. The proposed change will have no impact on any safety-related Structures, Systems, or Components.

The proposed change would revise the ERO requalification frequency from once every 12 months (plus a 25°/o grace period-three months) to annually (i.e., once per calendar year) as defined in the Exelon Nuclear Standardized Radiological Emergency Plan. The proposed change aligns the Exelon fleet under one standard regarding the annual requalification training frequency.

Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected sites does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

ATIACHMENT 1 License Amendment Revise Emergency Plan Requalification Training Frequency for Emergency Response Organization 9

10 The proposed change has no impact on the design, function, or operation of any plant The proposed change does not affect plant equipment or accident analyses.

The proposed change only affects the administration aspects of the annual ERO requalification training frequency requirements. There are no changes to the actual training conducted.

Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected sites does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There is no change being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by the proposed change to the frequency in the ERO requalification training requirements.

Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected sites does not involve a significant reduction in a margin of safety.

4.4 Conclusions In conclusion, based on the considerations discussed above: 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 issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements; (ii) changes to recordkeeping, reporting, or administrative procedures or requirements; (iii) changes to the licensee's or permit holder's name, phone number, business or e-mail address; (iv) changes to the name, position, or title of an officer of the licensee or permit holder, including but not limited to, the radiation safety officer or quality assurance manager; or (v) changes to the format of the license or permit or otherwise makes editorial, corrective or other minor revisions, including the updating of NRC approved references. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(1 0). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

ATIACHMENT 1 II'"'OI"C"O Amendment Request Mt:l\\/l<;!t:l Emergency Plan Requalification Training for Emergency Response Organization 10

6.0 REFERENCES

6.1 NRC Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011

ATTACHMENT 2 Markup of Emergency Plan Pages Limerick Generating Station, Units 1 and 2 EMERGENCY PLAN EP-AA-1008 Page: LGS 2-3

2.3 Emergency Response Organization (ERO) Training with of Plan per TQ-AA-11 no*""tnr*rY'I~~rt on an annual Oa!SIS~~~+a-l~~~~!l.s 2.4 Non-Exelon Nuclear Support Groups with or are verified current annually by the MA Region Group for the support agencies listed in Nuclear Radiological Emergency Plan Annex for LGS.

Nuclear has contractual agreements common within Exelon would be available in the event of racuot~oatcal emergency.

are also listed in Appendix 3 of the Nuclear Standardized Radiological Emergency Plan.

response coordination with governmental agencies and other support organizations is discussed in Section A of the Exelon Nuclear Standardized Plan.

2.5 Nuclear Steam Systems Supplier (NSSS)

Company maintains an Emergency Response Organization, which can provide technical assistance from their home office or at the site.

2.6 Architect/Engineer or other contractors may be involved in the technical analysis or with the emergency operation. Each such organization will designate a lead who will the same responsibilities, within their scope of work, as described for NSSS Contractor.

2013 LGS 2-3 EP-AA-1 008 (Revision 26)

ATTACHMENT 3 Markup of Emergency Plan Pages Oyster Creek Nuclear Generating Station EMERGENCY PLAN EP-AA-1010 Page: OCGS 2-4

An complement to support to the Full Augmentation facility access control measures.

in staffing are:

"-""-J"-.J......, 2-3) with Joint Information Center (JIC)

(ENC) functions, as described in Nuclear Standardized Radiological or consolidated with corresponding Media Monitoring and Rumor Control is not required because these functions are responsibility of State of NJ Office of Emergency Management Radiation Protection Spokesperson position was incorporated into the Technical Spokesperson Facilities Support Staff is not performed by designated individuals in the OCGS Emergency Plan logistical and administrative configuration of the OCGS EOF/JIC facilitates association between the ENC (Emergency News Center) and the JIC (Joint Information Center), where the Standard Plan associates the with in facility position assignments are shown below:

2.3 Emergency Response Organization (ERO) Training Training is conducted in with Section 0.5 of Standardized Radiological Emergency Plan per TQ-AA-113, Training and Qualification." Retraining is performed on an annual basis, *which is aefiReel es OCGS JIC/ENC staff will receive training on a periodic basis on their roles in responding to an emergency at the station per Section IL0.5.

2.4 Non-Exelon Nuclear Support Groups Agreements exist on file with or are verified current annually by the MA Region Corporate Emergency Preparedness Group for the support agencies listed in Appendix 2 of the Exelon Nuclear Radiological Emergency Plan Annex for OCGS.

Additionally, Exelon Nuclear has contractual agreements common within Exelon Nuclear with several companies whose services would be available in the event of a radiological emergency. These agencies are also listed in Appendix 3 of the Exelon Nuclear Standardized Radiological Emergency Plan.

June 2013 OCGS 2-4 EP-AA-1 01 0 (Revision 7)

ATTACHMENT 4 Markup of Emergency Plan Pages Peach Bottom Atomic Power Station, Units 1, 2, and 3 EMERGENCY PLAN EP-AA-1007 Page: PBAPS 2-3

No Information specified in 2.3 Emergency Response Organization (ERO) Training in with Radiological Plan Qualification.

Retraining is performed on an annual n~~~~~~-w.~rA-t~~~flll-f~

2.4 Non-Exelon Nuclear Support Groups Agreements exist on file with or are verified current annually by the MA Region Emergency Group for the following support agencies listed in Appendix 2 of the Exelon Nuclear Radiological Emergency Plan Annex for PBAPS.

Additionally, Exelon Nuclear has contractual agreements common within Exelon Nuclear with several companies whose services would be available in the event of a radiological emergency. These agencies are listed in Appendix 3 of the Exelon Nuclear Standardized Radiological Emergency Plan.

Emergency response coordination with governmental agencies and other support organizations is discussed in Section A of the Standard Plan.

2.5 Nuclear Steam Systems Supplier (NSSS)

General Electric Company maintains an Emergency Response Organization, which can provide technical assistance from their home office or at the site.

2.6 Architect/Engineer or other contractors may in the technical analysis or construction activities associated with the emergency response or recovery operation. Each such organization will designate a lead representative who will the same responsibilities, within their of work, as described for the NSSS Contractor.

June 2013 PBAPS 2-3 EP-AA-1 007 (Revision 27)

ATTACHMENT 5 Markup of Emergency Plan Pages Three Mile Island Nuclear Station, Units 1 and 2 EMERGENCY PLAN EP-AA-1009 Page: TMI 2-3

2.2 Emergency Response Organization (ERO) Staffing 1

the TMI Annex, "Minimum

, for a the Nuclear Radiological Emergency Plan of 60-minute full augmentation commitments.

An illustration of the overall Exelon ERO structure is in Figure TM I No changes in augmentation positions or staffing levels for the Technical Support Center (TSC) and Operations Support Center (OSC) from that specified in the Standard Plan.

Based on existing interface and staffing agreements, representatives from the Commonwealth of Pennsylvania will respond to the Emergency Operations Facility (EOF), allowing direct face-to-face communications. As such, the State Environs Communicator position, listed under the Standard Plan, is not staffed at the Coatesville EOF. Rather the EOF Environmental Coordinator will interface directly with State representatives present in the An Operations Assistant has been added to augment EOF staffing and provide TMI specific Operations knowledge in support of the existing Technical Support Manager and Operations Advisor positions.

Public Information Organization (Figure TMI No changes in augmentation positions or staffing for the Joint Information (JIC))

Emergency News Center (ENC) from that in the Exelon Nuclear Standardized Radiological Emergency Plan.

2.3 Emergency Response Organization (ERO) Training Training is conducted in accordance with Section of the Exelon Nuclear Emergency Plan per TQ-AA-113, "ERO Training and Qualification.

Retraining is performed on an annual TMI will offer training for hospital personnel, and ambulance and and departments required to support implementation of the TMI Plan. This training shall include the procedures for notification, basic radiation protection and their expected roles.

For those support organizations that must enter the site, training shall also include site access procedures and the identity (by title) of the individual in the site emergency organization who will control the organization's support activities.

June 2013 TMI 2-3 EP-AA-1 009 (Revision 21)