ML17081A290
| ML17081A290 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/24/2017 |
| From: | James Anderson NRC/NSIR/DPR |
| To: | Quinn V Federal Emergency Management Agency |
| Jeannette Arce | |
| References | |
| Download: ML17081A290 (4) | |
Text
March 24, 2017 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 OYSTER CREEK NUCLEAR GENERATING STATION EMERGENCY PLAN FOR PERMANENTLY DEFUELED CONDITION
Dear Ms. Quinn:
By letter dated February 28, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17060A289), Exelon Generation Company, LLC (Exelon) submitted for U.S. Nuclear Regulatory Commission (NRC) approval, a license amendment request (LAR) to the Radiological Emergency Plan (Emergency Plan) for Oyster Creek Nuclear Generating Station (OCNGS). The proposed changes to the OCNGS Emergency Plan would eliminate specific on-shift and augmented emergency response organization (ERO) positions based on written certification to the NRC under §50.82(a)(1) to Title 10 of the Code of Federal Regulations (10 CFR) of the permanent cessation of reactor operation and transfer of spent fuel from the reactor vessel. The proposed on-shift and ERO staffing changes are commensurate with the reduced spectrum of credible accidents from that of an operating power reactor or a power reactor with fuel remaining in the reactor vessel. 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.
Exelons February 28, 2017 letter contains the following attachments:
- , Description and Evaluation of Proposed Changes;
- , Tabular Summary of Proposed Changes to the Site Emergency Plan;
- , Proposed Revision to Site Emergency Plan;
- , Oyster Creek Summary Results of Post Shutdown On-Shift Staffing Technical Basis;
- , Emergency Response Organization Task Analysis;
- , Summary of Regulatory Commitments; and
- , Correspondence with State of New Jersey Table 2-1, OCNGS Minimum Staff Positions to Attachment 1 provides a comparison of current ERO positions and proposed post-shutdown ERO staffing. Section 5.3.4 to Attachment 1 provides Exelons evaluation of the impact to off-site response organizations.
V. Quinn On Page 48 to Attachment 1, Exelon specifically states, in part:
The proposed changes to the OCNGS Emergency Plan were evaluated for impacts on the ability of State and local response organizations to effectively implement their FEMA-approved REP plans. As evaluated in Attachment 5, the ERO functions and tasks that support or involve direct interface with State and local officials have been retained or transferred to another ERO position.
In its February 28, 2017 letter, Exelon indicated that on November 29, 2016, the New Jersey (NJ) Department of Environmental Protection Bureau of Nuclear Engineering (BNE) received the draft proposed changes of the OCNGS Emergency Plan and that on January 17, 2017, a meeting was held with the BNE in Trenton, NJ, to discuss these proposed changes. to Exelons February 28, 2017 letter documents these discussions and contains:
Letter from Patrick Mulligan, Manager BNE to Michael P. Gallagher, Vice President, License Renewal & Decommissioning, Exelon, dated January 24, 2017, confirming that BNE completed its initial review of the OCNGS LAR; Exelons response to the BNEs questions, concerns, and requests dated February 10, 2017; and BNEs response to Exelon's resolution of comments, dated February 24, 2017.
The NRCs initial review of the proposed OCNGS Emergency Plan indicates that these changes would not impact the methods or timing for the notification of State and local agencies of an emergency declaration and/or offsite protective action recommendation, offsite radiological monitoring and assessment capabilities, or the current location of licensee emergency response facilities. However, due to the extent of proposed changes to the licensees ERO, specifically at the OCNGS Emergency Operations Facility and Joint Information Center, I am requesting FEMA's review of the proposed licensee staffing changes, against the current FEMA-approved State and local Radiological Emergency Preparedness (REP) plans to verify that no potential adverse impacts exist that would preclude the effective implementation of State and local REP plans.
By letter dated January 7, 2011 (ADAMS Accession No. ML110070507), Exelon provided formal notification to the NRC of Exelons contingent determination to permanently cease power operations at OCNGS no later than December 31, 2019. In this letter, Exelon also requested NRC approval of the OCNGS LAR prior to the docketing of the certifications required by 10 CFR 50.82(a)(1) that OCNGS has been permanently defueled. Exelon would implement proposed changes within 60 days of docketing of certifications, but by no later than March 29, 2020. However, based on the number of on-going and projected decommissioning-related licensing actions, I am requesting that FEMA provide its assessment to the NRC by no later than May 26, 2017, to support any further request for additional information to Exelon.
In Attachment 1 to the February 28, 2017 letter, Exelon stated:
OCNGS will perform a drill 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 being developed depicting the revised assignment of duties. 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
V. Quinn offered the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities.
Additionally, Attachment 7 of Exelons February 28, 2017 letter, provides in their response letter to the State of New Jersey, dated February 10, 2017, for Issue 2.d, Reduced Staffing and Training Drills:
Both the BNE and NRC will be invited to observe and participate in the OCNGS demonstration drill. BNE is welcome to perform observations at any of the Exelon emergency response facilities. Under this Emergency Plan, BNE would be invited to participate in OCNGS exercises in a similar manner as is done currently.
As always, thank you for your assistance. If you have any questions regarding the specifics of the changes requested to the OCNGS Emergency Plan, the NRCs evaluation of these proposed changes, or will be unable to meet the requested due date of May 26, 2017, 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
SUBJECT:
LICENSE AMENDMENT REQUEST - PROPOSED CHANGES TO THE OYSTER CREEK NUCLEAR GENERATING STATION EMERGENCY PLAN FOR PERMANENTLY DEFUELED CONDITION DATED: March 24, 2017 Distribution:
M. Norris, NSIR R. Kinard, NSIR R. McKinley, Region I D. Tifft, Region I J. Gleaves, Region I D. Broaddus, NRR J. Lamb, NRR ADAMS Accession Number: ML17081A290 OFFICE NSIR/DPR NSIR/DPR:TL NSIR/DPR:BC NAME RKinard MNorris JAnderson DATE 03/23/17 03/24/17 03/24/17 OFFICIAL RECORD COPY