ML18096B078

Summary of Meeting with Exelon Generation Company, LLC, on Planned Submittal of License Amendments Concerning Emergency Operation Facility and Technical Support Center (EPID L-20118-LRM-0016)

ML18096B078
Person / Time
Site:	Calvert Cliffs
Issue date:	04/12/2018
From:	Marshall M Plant Licensing Branch 1
To:	Bryan Hanson Exelon Generation Co
Marshall M, NRR/DORL/LPLI, 415-2871
Shared Package
ML18096B118	List: ML18096B078
References
EPID L-2018-LRM-0016
Download: ML18096B078 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 12, 2018 LICENSEE: Exelon Generation Company, LLC FACILITY: Calvert Cliffs Nuclear Power Plant, Units 1 and 2

SUMMARY

OF MARCH 12, 2018, MEETING WITH EXELON GENERATION COMPANY, LLC, ON PLANNED SUBMITTAL OF LICENSE AMENDMENTS CONCERNING EMERGENCY OPERATION FACILITY AND TECHNICAL SUPPORT CENTER (EPID L-2018-LRM-0016)

On March 12, 2018, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC (Exelon, the licensee) via telephone conference. The purpose of the meeting was to discuss the proposed license amendment requests (LARs) to relocate the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs), emergency operations facility (EOF) and technical support center (TSC). Most of the discussion during the telephone conference was focused on the relocation of the EOF. The meeting notice and agenda, dated February 26, 2018, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML180578166. The presentation material used by the licensee is available in ADAMS at Accession No. ML18096A990. A list of attendees is provided in the Enclosure.

Proposed LAR to Relocate EOF During their presentation, the Exelon representatives stated that the licensee planned to submit an LAR to relocate the Calvert Cliffs EOF and joint information center to Coatesville, Pennsylvania in June 2018. Exelon, currently, has an EOF in Coatesville that is shared by Limerick Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station. The Exelon representatives stated that recent precedents would be considered in the preparation of the proposed LAR. For example, based on precedents, the proposed submittal would address simultaneous events at multiple stations, training of corporate personnel on the Calvert Cliffs plant technology, and communications. Additionally, the licensee described discussions and interactions it has had to date with state agencies and local governments in the State of Maryland. The licensee stated that the planned LAR would be independent (i.e., no linkage) of a related planned fleet LAR concerning emergency response organization staffing that would also be submitted in June 2018.

The NRC staff informed the licensee that:

• The Commission is interested in drills involving multiple stations that have differing plant technology.

• Reviews of EOF relocations greater than 25 miles would involve Commission approval and consultation with the Federal Emergency Management Agency.

• It should consider the guidance for near-site facilities in NUREG-0696, "Functional Criteria for Emergency Response Facilities," dated February 1981 (ADAMS Accession No. ML051390358) and NSIR/DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants," dated November 2011 (ADAMS Accession No. ML113010523).

• As part of the review, the NRC staff would conduct a regulatory audit at the facility in Coatesville.

The NRC staff suggested that the licensee include in its submittal:

• Descriptions of relevant agreements with the State of Maryland.

• Description of any changes to interfaces with offsite agencies.

• Discussion concerning the ability to cope with simultaneous events at the EOF.

• Description of any historical information pertaining to simultaneous events.

• Description of an assessment of response to events at more than one station.

• Discussion on the periodicity of multiple station drills.

• Specific details concerning the training of corporate personnel on Calvert Cliffs.

• Discussion reliability and redundancy of communications (e.g., satellite phones, cellular phones) within the emergency planning zone and EOF.

Proposed LAR to Relocate TSC During their presentation, the Exelon representatives stated that the licensee is considering relocating the Calvert Cliffs TSC from its location near the control room to outside of the protected area in the site Nuclear Office Facility. The Exelon representatives described the goals for the TSC relocation and the precedents that the licensee is considering. The licensee stated that the soonest that it would submit the LAR would be the end of calendar year 2018.

In response to a question from the Exelon representatives, the NRC staff informed the licensee that the LAR for Donald C. Cook Nuclear Plant (ADAMS Accession No. ML18024A447) would be a good precedent to consider. The NRC staff suggested that the licensee address, in its submittal, the consideration of location of the personnel that would staff the TSC and the "2-minute" rule.

Public Comments and Questions Members of the public attended the telephone conference. During the telephone conference, representatives from the State of Maryland asked questions of the NRC staff concerning:

• The States consultation on the relocation of the EOF review.

• The States consultation on the relocation of the joint information center.

The NRC staff informed the representative of the State of Maryland that the NRC's Calvert Cliffs operating reactor project manager would keep them informed on the progress of the review of the licensee proposed LAR and would consult, as required, with the State prior to issuing a decision on the proposed LAR. Additionally, the licensee stated that it is committed to keeping the State involved, including participation in a demonstration drill.

A public meeting feedback form was received. The question received via the feedback form was:

How can [NRC] Inspection Procedure [IP] 71114.06 be accomplished, if the EOF is a significant distance from the site? Either more resources are needed or the

[inspection procedure] needs to be revised.

The NRC IP 71114.06, "Drill Evaluation," issued July 9, 2002 (ADAMS Accession No. ML021900257), is an inspection procedure assigned to resident inspectors. The procedure's objectives are to evaluate the licensee's ability to properly conduct a drill and effectively critique a broad spectrum of emergency preparedness (EP) related drills and or training evolutions between NRC-graded EP exercises. There is no inspection requirement, guidance, or expectation that the evaluation of the drill/exercise or training be performed from a specific emergency response facility (ERF).

Existing consolidated EOFs, which support multiple sites (e.g., Exelon - Mid-West & Mid-Atlantic, Duke Energy Corporation and Southern Nuclear Operating Company), are normally observed by Regional EP Inspectors during a scheduled biennial exercise. The NRC IP 71114.01, "Exercise Evaluation," issued July 9, 2002 (ADAMS Accession No. ML021900205) is used to evaluate the licensee's capability to assess performance for the ERF via a formal critique process in order to identify and correct weaknesses associated with the planning standard under Title 10 of the Code of Federal Regulations Section 50.47(b)(14).

The feedback form has been forwarded to the NRR Senior Communications Analyst who will forward it to the Office of the Executive Director for Operations.

No regulatory decisions were made during the public telephone conference. Please direct any inquiries to me at (301) 415-2871 or Michael.Marshall@nrc.gov.

Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES MARCH 12, 2018, MEETING WITH EXELON GENERATION COMPANY, LLC, ON PLANNED SUBMITTAL OF LICENSE AMENDMENTS CONCERNING EMERGENCY OPERATION FACILITY AND TECHNICAL SUPPORT CENTER

• AT:TENDEE Paula Amos Exelon Generation Company, LLC (Exelon)

Joe Andersen U.S. Nuclear Regulatory Commission (NRC)

John Costello Dominion Energy Services Vince Cwietniewicz Exelon Vicki Foster NRC Deyanara Gonzalez Lainez NRC Susan Gray State of Maryland (MD)

Michael Griffen MD Richard Gropp Exelon Dave Gudger Exelon Avinash Jaigobind NRC Amanda Marshall NRC Michael Marshall NRC Michael Norris NRC PaulRades NRC Shawn Seaman MD Shauna Stoy Exelon Chanel Stridiron NRC David T ancabel MD John Thorp NRC Doug Walker Exelon

Package: ML18096B118 Meeting Notice: ML18057B166 Meeting Summary: ML18096B078 Handouts: ML18096A990 OFFICE NRR/DORL/LPL 1/PM NRR/DORL/LPL 1/LA NRR/DORL/LPL 1/BC NRR/DORL/LPL 1/PM NAME MMarshall IBetts JDanna MMarshall DATE 04/11/18 04/10/18 04/12/18 04/12/18