ML16356A480

NRR E-mail Capture - RAIs on TMI License Amendment Request for Approval of Changes to the Three Mile Island Nuclear Station Emergency Plan Related to Staffing

ML16356A480
Person / Time
Site:	Three Mile Island
Issue date:	12/21/2016
From:	Justin Poole Plant Licensing Branch 1
To:	Gropp R, Mascitelli F Exelon Corp
References
Download: ML16356A480 (3)

Text

NRR-PMDAPEm Resource From: Poole, Justin Sent: Wednesday, December 21, 2016 11:53 AM To: 'Mascitelli, Francis J:(GenCo-Nuc)'; 'Gropp Jr, Richard W:(GenCo-Nuc)'

Subject:

RAIs on TMI ERO staffing amendment Attachments: MF8147 RAI.docx Frank/Richard, 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). On December 1, 2016, I sent, via email (ML16XXXAXXX) a DRAFT request for additional information (RAI). On December 13, 2016, a clarification call was held between the NRC staff and Exelon regarding this RAI. The outcome of the call was that no modification to the RAI was needed. As such, per LIC-101, I am re-sending the RAI sent on December 1, 2016, as a formal RAI. During a follow-up call on December 15, you requested a response date of January 31, 2017. The NRC staff agrees with this proposed date. When responding to the RAI, please reference this email (it will be placed in ADAMS and I will provide you the Accession number at a later date) and repeat back the RAI in your response.

If you have an questions, feel free to contact me.

Thanks.

1

Hearing Identifier: NRR_PMDA Email Number: 3224 Mail Envelope Properties (7c41f3acbb554aacb28dd911538642cd)

Subject:

RAIs on TMI ERO staffing amendment Sent Date: 12/21/2016 11:52:37 AM Received Date: 12/21/2016 11:52:37 AM From: Poole, Justin Created By: Justin.Poole@nrc.gov Recipients:

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

Tracking Status: None

"'Gropp Jr, Richard W:(GenCo-Nuc)'" <Richard.Gropp@exeloncorp.com>

Tracking Status: None Post Office: HQPWMSMRS04.nrc.gov Files Size Date & Time MESSAGE 1180 12/21/2016 11:52:37 AM MF8147 RAI.docx 28412 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

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.