ML16328A400

NRC Letter to FEMA Re NRC Not Requesting FEMA Review Re License Amendment Request - Proposed Changes to the Clinton Power Emergency Plan for Permanently Defueled Condition

ML16328A400
Person / Time
Site:	Clinton
Issue date:	11/28/2016
From:	James Anderson NRC/NSIR/DPR
To:	Quinn V US Dept of Homeland Security, Federal Emergency Management Agency
Joseph Anderson
References
Download: ML16328A400 (4)

Text

November 28, 2016 Vanessa Quinn, Chief Radiological Emergency Preparedness Branch Technological Hazards Division Federal Emergency Management Agency - Area 8 400 C Street, South West Washington, DC 20024

SUBJECT:

LICENSE AMENDMENT REQUEST - PROPOSED CHANGES TO THE CLINTON POWER STATION EMERGENCY PLAN FOR PERMANENTLY DEFUELED CONDITION

Dear Ms. Quinn:

By letter dated August 11, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16229A278 - package), Exelon Generation Company LLC submitted a license amendment request to the Radiological Emergency Plan Annex for Clinton Power Station (CPS), proposing reductions in emergency response organization (ERO) staff to be implemented upon written certification to the U.S. Nuclear Regulatory Commission (NRC) under §50.82(a)(1)(i) and (ii) to Title 10 of the Code of Federal Regulations (10 CFR) of the permanent cessation of reactor operation and permanent removal of fuel from the reactor vessel. The proposed changes to the CPS Radiological Emergency Plan Annex would eliminate specific on-shift and augmented emergency response organization (ERO) staffing based on the permanently shutdown and defueled condition of the facility, which is commensurate with the reduced spectrum of credible accidents. These proposed changes are not associated with any requests for exemption to NRC regulations and must continue to meet the standards of 10 CFR 50.47, Emergency plans, and the requirements of Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities.

Based on our on-going review, NRC staff has determined that the proposed changes to reduce ERO staffing commensurate with the permanently shutdown condition of the facility are limited to onsite ERO functions. As such, at this time NRC is not requesting FEMAs formal review of the potential impact of changes on the ability of States and local authorities to implement their FEMA-approved plans. NRCs determination is based on the following:

• The proposed reductions to on-shift staffing, ERO minimum staffing (60-minute responders), and ERO augmented staffing, as described in Sections 2.1 through 2.3 to Attachment 1 of Exelon Generations letter dated August 11, 2016, would not result in any reductions in the ERO minimum and augmented staffing levels at the Exelon Corporate Emergency Operations Facility (EOF) or Joint Information Center (JIC), nor change the location and activation timeliness requirements for these facilities, which serve as the primarily licensee interface with State and local response agencies and the public.

V. Quinn

• Section 5.3.4 (Assessment of Staff Changes on Off-Site Emergency Response Organizational Interfaces) to Attachment 1 of Exelon Generations letter dated August 11, 2016, describes that actions involving support or direct interface with the State of Illinois are not being revised and will continue to be performed by licensee ERO positions currently assigned. While Exelon Generation proposes to eliminate the TSC State/Local Communicator position, this position is currently listed as an ERO augmented (non-minimum staffing) position. Exelon Generation now proposes to transfer responsibility for event notifications directly from the Control Room to the EOF, which will still be required to be activated at an Alert or higher classification.

• Methods and timing, as well as content of messages, for the notification of designated State and local agencies for event declaration and protective action recommendations remain unchanged.

• Continued maintenance of licensee letters of agreement with various support organizations and local emergency response agencies, as listed in Appendix 2 of the proposed CPS Radiological Emergency Plan Annex.

• Exelon Generations engagement with the Illinois Emergency Management Agency (IEMA) and the primary affected county for CPS (DeWitt County) to discuss and familiarize these organizations with the proposed changes to the CPS Radiological Emergency Plan Annex. The NRC will continue to keep FEMA apprised of any correspondence received from the State of Illinois regarding discussion with Exelon Generation on the proposed CPS Radiological Emergency Plan Annex and associated emergency action level (EAL) scheme change.

This letter does not constitute NRC approval of proposed changes to the CPS Radiological Emergency Plan Annex, but rather to inform FEMA that at this time the NRC will not be requesting a formal FEMA review of the potential impact of changes on the ability of States and local authorities to implement their FEMA-approved plans. to Exelon Generations letter dated August 11, 2016, identifies a regulatory commitment that CPS will perform a drill, prior to implementation of the Post-Shutdown Emergency Plan, to confirm the ability of the post-shutdown ERO to perform the necessary functions of each emergency response facility and to utilize the post-shutdown procedures. The regulatory commitment further states:

The drill will involve a spent fuel pool event that tests the major elements of the licensees emergency plan and communications/coordination with offsite response organizations, including the Joint Information Center. State and local response organizations will be offered the opportunity to participate, and NRC and FEMA will be provided advance notice to observe drill activities.

This drill will provide the opportunity for FEMA to observe the continued adequacy of existing State and local radiological emergency plans under the existing FEMA drill/exercise process.

V. Quinn As always, if you have any questions regarding the specifics of the proposed changes to the Exelon Nuclear Clinton Radiological Emergency Plan and CPS Annex, or the NRC's evaluation of these proposed changes, please contact Richard Kinard at (301) 287-3768.

Sincerely,

/RA/

Joseph D. Anderson, Chief Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response cc: J. King, FEMA HQ

V. Quinn The drill will involve a spent fuel pool event that tests the major elements of the licensees emergency plan and communications/coordination with offsite response organizations, including the Joint Information Center. State and local response organizations will be offered the opportunity to participate, and NRC and FEMA will be provided advance notice to observe drill activities.

This drill will provide the opportunity for FEMA to observe the continued adequacy of existing State and local radiological emergency plans under the existing FEMA drill/exercise process.

As always, if you have any questions regarding the specifics of the proposed changes to the CPS Radiological Emergency Plan Annex, or the NRC's evaluation of these proposed changes, please contact Richard Kinard at (301) 287-3768.

Sincerely,

/RA/

Joseph D. Anderson, Chief Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response cc: J. King, FEMA HQ Distribution:

M. Norris, NSIR S. Orth, RIII H. Peterson, RIII A. Barker, RIII H. Logaras, RIII R. Kinard, NSIR R. Hoffman, NSIR ADAMS Accession Number: ML16328A400 OFFICE NSIR:DPR TL:NSIR:DPR BC:NSIR:DPR NAME RHoffman MNorris JAnderson DATE 11/28/16 11/28/16 11/28/16 OFFICIAL RECORD COPY