ML16337A007

NRR E-mail Capture - Draft RAIs Three Mile Island Nuclear Station, Units 1 and 2, License Amendment Request for Approval of Changes to the Three Mile Island Nuclear Station Emergency Plan Related to Staffing

ML16337A007
Person / Time
Site:	Three Mile Island
Issue date:	12/01/2016
From:	Justin Poole Plant Licensing Branch 1
To:	Mascitelli F Exelon Corp
References
MF8147, TMI-16-073
Download: ML16337A007 (3)

Text

NRR-PMDAPEm Resource From: Poole, Justin Sent: Thursday, December 01, 2016 2:44 PM To: Mascitelli, Francis J:(GenCo-Nuc)

Subject:

DRAFT RAIs on TMI ERO Staffing amendment Attachments: MF8147 DRAFT RAI.docx

Frank, By letter dated July 15, 2016, Exelon Generation Company, LLC (Exelon) requested NRC approval for on-shift emergency response staffing modifications as described in Table TMI 2-1, "Minimum Staffing Requirements for TMI [Three Mile Island] Station" of the Radiological Emergency Plan Annex for TMI, Units 1 and 2 (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML16201A306). In reviewing the application, the NRC staff has developed the attached DRAFT request for additional information (RAI). Please review to ensure that the RAI question is understandable, the regulatory basis is clear, there is no proprietary information contained in the RAI, and to determine if the information was previously docketed. If further clarification is needed, and you would like to discuss the questions in a conference call, let us know. This email does not convey a formal NRC staff position, and it does not formally request for additional information.

Thanks.

Justin C. Poole Project Manager NRR/DORL/LPLI-2 U.S. Nuclear Regulatory Commission (301)415-2048 1

Hearing Identifier: NRR_PMDA Email Number: 3193 Mail Envelope Properties (1b0414d1e73a493eaa688bad103c616d)

Subject:

DRAFT RAIs on TMI ERO Staffing amendment Sent Date: 12/1/2016 2:43:55 PM Received Date: 12/1/2016 2:43:56 PM From: Poole, Justin Created By: Justin.Poole@nrc.gov Recipients:

"Mascitelli, Francis J:(GenCo-Nuc)" <Francis.Mascitelli@exeloncorp.com>

Tracking Status: None Post Office: HQPWMSMRS01.nrc.gov Files Size Date & Time MESSAGE 1097 12/1/2016 2:43:56 PM MF8147 DRAFT RAI.docx 29155 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

DRAFT REQUEST FOR ADDITIONAL INFORMATION THREE MILE ISLAND NUCLEAR STATION, UNIT 1 AND 2 NRC DOCKET NOS. 50-289 and 50-320 By letter dated July 15, 2016, Exelon Generation Company, LLC (Exelon) requested prior NRC approval for on-shift emergency response staffing modifications as described in Table TMI 2-1, "Minimum Staffing Requirements for TMI [Three Mile Island] Station" of the Radiological Emergency Plan Annex for TMI, Units 1 and 2 (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML16201A306).

The request for additional information (RAI) below is needed to facilitate the Reactor Licensing Branch staffs technical review of the proposed staffing changes.

TMI-RAI 1:

Regulatory Issue Summary (RIS) 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (ADAMS Accession No. ML16124A002), states, in part; In support of a proposed LAR [license amendment request], a licensee should supply sufficient information to allow the NRC to conclude independently that a proposed alternate staffing approach supports timely and effective performance of the Major Functional Areas and Major Tasks listed in Table B-1 of NUREG-0654.

The following paragraph from Section 3.0, Technical Evaluation, has been repeated throughout Exelons justification for all of the proposed changes:

The required tasks for each event were assessed to determine if sufficient personnel are available on-shift to perform all of the tasks required by the applicable plant procedures and the Emergency Plan, without the need for any unacceptable collateral duties. This assessment concluded that the minimum on-shift staff of [insert the specific change being evaluated] is sufficient to perform all required tasks prior to augmentation. The TMI on-shift staffing assessment is included in Attachment 4 [EP-AA-1009, Addendum 1, Three Mile Island On-shift Staffing Technical Basis] of this submittal.

For each change, TMI has used the assessment reflected in Attachment 4 as the basis for our acceptance. However, the assessment provided in Attachment 4 is the current assessment used to meet §IV.A.9 to Appendix E of 10 CFR Part 50, and not an assessment of shift staffing with all the proposed changes in place. As a result, the evaluation performed by TMI to justify these changes was not provided and, therefore, the staff cannot independently conclude that the proposed changes will not cause an issue where emergency planning functions would not be the highest priority for a member of the on-shift staff to perform as assigned.

Please provide a revised assessment reflective of the proposed changes in support of the staffs continued technical review of the proposed staffing changes to independently conclude that the changes, as proposed, continue to meet the regulations and maintain reasonable assurance of adequate public health and safety.