ML18085B172
| ML18085B172 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/04/2018 |
| From: | James Anderson NRC/NSIR/DPR/RLB |
| To: | Quinn V Federal Emergency Management Agency |
| Richard Kinard | |
| References | |
| Download: ML18085B172 (4) | |
Text
April 4, 2018 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:
FEDERAL EMERGENCY MANAGEMENT AGENCY REVIEW REQUESTED OF REVISION TO THE THREE MILE ISLAND NUCLEAR STATION EMERGENCY PLAN FOR POST-SHUTDOWN AND PERMANENTLY DEFUELED CONDITION
Dear Ms. Quinn:
By letter dated June 20, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17171A151), Exelon Generation Company, LLC (Exelon) provided formal notification to the U.S. Nuclear Regulatory Commission (NRC), pursuant to sections 50.4(b)(8) and 50.82(a)(1)(i) of Title 10 to the Code of Federal Regulations (10 CFR), of its determination to permanently cease power operations at the Three Mile Island Nuclear Station, Unit 1 (TMI) on or about September 30, 2019. In preparation for the permanent cessation of operations at TMI, by letter dated March 19, 2018 (ADAMS Accession No. ML18078A578),
Exelon submitted for prior NRC approval, a license amendment request (LAR) to the TMI Site Emergency Plan (SEP). Refer to URL below to access the LAR submittal.
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18078A578 The proposed changes to the TMI SEP would revise the licensees on-shift and augmented emergency response organization (ERO) positions, based on written certification to the NRC pursuant to 10 CFR 50.82(a)(1) for the permanent cessation of reactor operation and transfer of spent fuel from the reactor vessel. The proposed licensee on-shift and augmented 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.
In addition, Exelon proposed to remove remaining ERO positions from the TMI SEP that are not required to meet the minimum staffing guidance contained in Table B-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies, to NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. These designated full augmentation positions, which would not be required to activate their respective emergency response facility, would be managed and controlled under the stations emergency plan implementing procedures.
V. Quinn Attachment 1, Description and Evaluation of the Proposed Changes, to Exelons March 19, 2018 letter provides a description and evaluation of the proposed licensee on-shift and augmented ERO staffing changes. Table 2-1, TMI Minimum Staff Positions, and Table 2-2, TMI Augmented Staff Position Disposition, to Attachment 1 provide a comparison of the current augmented ERO positions against the proposed post-shutdown augmented ERO positions. Section 5.4, Assessment of Staff Changes on Off-site Response Organizational Interfaces, to Attachment 1 provides Exelons evaluation of impact of the proposed licensee ERO staffing changes against the existing Federal Emergency Management Agency (FEMA)-
approved radiological emergency preparedness (REP) plans.
On February 13, 2018, Exelon provided the Commonwealth of Pennsylvania, Department of Environmental Protection / Bureau of Radiation Protection (DEP/BRP), with a draft copy of the proposed TMI SEP for comment. An electronic mail from the DEP/BRP dated March 8, 2018, provided as Attachment 6 to Exelons March 19, 2018 letter, confirmed completion of the Commonwealths review prior to formal submission of the LAR to the NRC and indicated that DEP/BRP had no further comments at this time.
The NRCs initial review of the proposed TMI SEP 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 or timing of activation for the licensees emergency response facilities. However, due to the extent of proposed changes to the licensees ERO staffing, the NRC is requesting FEMA's review of the proposed licensee ERO staffing changes to verify that no potential adverse impacts exist that would preclude the effective implementation of State and local REP plans.
Exelon requests that the amendment, once approved, become effective following submittal of the docketing of the certifications required by 10 CFR 50.82(a)(1) that TMI Unit 1 has been permanently defueled. Once the TMI Unit 1 reactor vessel has been permanently defueled, implementation of the proposed TMI SEP, if approved by the NRC, would occur within 90 days, but will not exceed December 31, 2019. However, based on the significant number of on-going and projected licensing actions, I am requesting that FEMA provide its assessment to the NRC by no later than June 8, 2018, to support any further request for additional information to Exelon, as needed to support the NRCs continued technical review and final determination. , Summary of Regulatory Commitments, to Exelons March 19, 2018, letter states that prior to implementation of the proposed TMI SEP:
TMI 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. State and local response organizations will be offered the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities. In addition, other training drills will be conducted to train post-shutdown station ERO members.
V. Quinn As always, thank you for your assistance. If you have any questions regarding the specifics of the changes requested to the PNPS SEP; the NRCs evaluation of these proposed changes, or if FEMA will be unable to meet the requested due date of June 8, 2018, 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: C. Fiore, FEMA HQ T. Scardino, FEMA Region III
V. Quinn
SUBJECT:
FEDERAL EMERGENCY MANAGEMENT AGENCY REVIEW REQUESTED OF REVISION TO THE THREE MILE ISLAND NUCLEAR STATION EMERGENCY PLAN FOR POST-SHUTDOWN AND PERMANENTLY DEFUELED CONDITION DATED: 04/04/18 DISTRIBUTION:
M. Norris, NSIR R. Kinard, NSIR J.D. Anderson, NSIR D. Tifft, Region I D. Broaddus, NRR J. Poole, NRR R. McKinley, Region I J. Greives, Region I R. Powell, Region I ADAMS Accession Number: ML18085B172 OFFICE NSIR/DPR NSIR/DPR:TL NSIR/DPR:BC NAME R. Kinard M. Norris J. D. Anderson DATE 04/03/18 04/04/18 04/04/18 OFFICIAL RECORD COPY