ML18120A177
| ML18120A177 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Three Mile Island, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  |
| Issue date: | 05/01/2018 |
| From: | Blake Purnell Plant Licensing Branch III |
| To: | Exelon Generation Co |
| Purnell B, NRR/DORL/LPLIII, 415-1380 | |
| References | |
| EPID L-2018-LRM-0028 | |
| Download: ML18120A177 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 1, 2018 LICENSEE: EXELON GENERATION COMPANY, LLC FACILITIES: BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2; CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; JAMES A FITZPATRICK NUCLEAR POWER PLANT; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; R. E. GINNA NUCLEAR POWER PLANT; AND THREE MILE ISLAND NUCLEAR STATION, UNIT 1
SUBJECT:
SUMMARY
OF APRIL 26, 2018, MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING DRAFT GUIDANCE FOR EMERGENCY RESPONSE ORGANIZATION STAFFING (EPID L-2018-LRM-0028)
On April 26, 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 teleconference. The purpose of the meeting was to discuss draft guidance for emergency response organization (ERO) staffing. The meeting notice and agenda, dated April 13, 2018, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML18103A036. A list of attendees and the licensee's handout used at the meeting are enclosed.
Currently, Revision 2 to NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (ADAMS Accession No. ML14163A605), is being developed. The proposed changes include a revision to the minimum staffing requirements, which are described in draft Table B-1, "Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies" (ADAMS Accession No. ML17083A815). Exelon is planning 1 on revising its ERO staffing based on this draft guidance for most of its facilities. As of the date of this meeting, Exelon has submitted a license amendment request (LAR) for its Midwest facilities to make these changes (ADAMS Accession No. ML18053A159).
One of the proposed changes to Table B-1 is the removal of the chemistry technician function because it is no longer needed as the need for immediate reactor coolant sampling has been reduced due to the variety of plant indications of fuel damage available to licensees. As discussed in its handout, Exelon wanted additional clarification regarding this change because certain emergency action levels (EALs) are based on chemical sample analyses.
1 See ADAMS Accession No. ML173478102.
The NRC staff noted that the chemistry technician was listed in NUREG-0654 because of the need for immediate sample functions. If this function is not needed for emergency response, then it is not necessary to list a chemical technician as part of the ERO staff. The EALs do not specifically require a chemical technician.
Two state officials asked if the ability to take effluent samples will be retained. The NRC staff noted that the requirements for sampling are part of the technical specifications, and these requirements are not affected by emergency plan changes. Additionally, the EALs use sample results, but do not direct samples to be taken.
Exelon stated that it will supplement its LAR for its Midwest facilities because it stated that the chemistry technician would be retained.
Public meeting feedback forms were not received. Please direct any inquiries to me at 301-415-1380, or Blake.Purnell@nrc.gov.
Blake Purnell, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-333, 50-373, 50-37 4, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, 50-244, and 50-289
Enclosure:
- 1. List of Attendees
- 2. Exelon Handout cc: Listserv
LIST OF ATTENDEES APRIL 26, 2018, MEETING WITH EXELON GENERATION COMPANY, LLC Name Affiliation Blake Purnell NRC Joe Anderson NRC Michael Norris NRC Richard Kinard NRC Larry Baker Exelon DouQ Walker Exelon Mike Slaby Exelon Mark Friedmann Exelon Richard Gropp Exelon Rodney Brown Enerav Compliance Consultants, LLC Diane Coffin Southern Nuclear Ricky Collings Southern Nuclear David Lafleur Pennsylvania Department of Environmental Protection Rich Janati Pennsylvania Department of Environmental Protection Patrick Mulligan New Jersey Department of Environmental Protection Ann Pfaff New Jersey Department of Environmental Protection Eric White Duke EnerQy Daniel King Columbia Generating Station Lori Tkaczyk Enercon Services, Inc.
Bob Kidwell Enercon Services, Inc.
John Conly Certrec Corporation Enclosure 1
EXELON HANDOUT Teleconference Briefing Notes 04/26/18 In reviewing the guidance in draft Revision 2 of NUREG-0654 for ERO staffing, it is noted that the Chemistry Technician is not included on the Shift Staffing Table B-1. The accompanying NRC Technical Basis document for the draft ERO guidance provides the following insight:
The Chemistry/Rad Chemistry function listed in Table B-1 to Revision 1 of NUREG-0654/FEMA-REP 1, is no longer needed as the need for immediate reactor coolant sampling has been reduced due to the variety of plant indications of fuel damage available to licensees.
Discussion Points
- It is understood that a License Amendment is required to revise Emergency Plan staffing requirements, which includes an On-Shift Staffing Assessment and a functional analysis of NUREG-0654, Table B-1 Emergency Preparedness (EP) Functions and Tasks.
- Further clarification would be helpful in determining whether additional Emergency Plan changes would be required to support removal of the Chemistry Technician (e.g.,
Emergency Action Levels (EALs)).
- Certain EALs under the NEI 99-01, Revision 6 guidance reference sample analysis (some examples are cited below for reference). Clarification would be helpful in determining whether a Shift Chemist would be required 24/7 to support classification of these EALs.
o NEI 99-01, Revision 6 - provides guidance for some of these EALs with respect to alternate EAL thresholds which rely on hand held or deployed detectors in place of the sample analysis. But the guidance does not seem to be consistently written for all of the referenced chemistry sample related EALs.
o NEI 99-01, Revision 6 - also discusses samples in terms of requiring "several hours to complete" and that the "sample-related threshold is included as a backup to other indications."
o It is noted that Reactor Coolant System (RCS) samples are taken on a scheduled frequency when a Chemistry Technician would be scheduled to be available, or are required 2-6 hours following a power change, where a Chemistry Technician could be called in. Further clarification would helpful for determining if this is adequate justification for no longer requiring Chemistry Technicians on shift to support EAL classification.
Supporting Information - NEI 99-01, Revision 6 EALs Related to Chemistry Sampling
- Fission Product Barrier Matrix - Fuel Clad Barrier Thresholds Threshold #1 - Reactor Coolant Activity Level - Loss - This value indicates that RCS activity is in excess of 300 mCi/gm dose equivalent 1-131.
Enclosure 2
It is recognized that RCS sampling and analysis activities, particularly those involving samples with elevated activity levels, could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications.
The threshold value should be expressed as either a dose rate measured on the sample or radioactivity concentration such as mCi/gm or mCi/cc.
- SU3 - Initiating Condition: Fuel clad degradation greater than Technical Specification allowable limits.
Threshold #2 - Reactor coolant sample activity greater than (site-specific Technical Specification allowable limits). EAL #2 addresses reactor coolant sample results that are beyond those allowed by Technical Specifications.
Note that SU3, EAL Threshold #1 allows for a hand-held monitor or deployed detector reading with pre-calculated conversion values or readily implementable conversion calculation capability in place of the installed radiation monitor.
- AU1 - Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer Threshold #3 - Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer.
EAL #3 - This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g.,
spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).
- AA 1 - Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEOE or 50 mrem thyroid COE.
Threshold #3 - Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEOE or 50 mrem thyroid COE at or beyond (site-specific dose receptor point) for one hour of exposure.
When considering the available draft NUREG-0654, Revision 2 guidance, additional clarification is requested regarding the commitment related to on-shift chemistry staffing.
SUBJECT:
SUMMARY
OF APRIL 26, 2018, MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING DRAFT GUIDANCE FOR EMERGENCY RESPONSE ORGANIZATION STAFFING (EPID L-2018-LRM-0028) DATED MAY 1, 2018 DISTRIBUTION:
PUBLIC RidsNrrPMLaSalle Resource RidsNrrDorlLpl1 Resource RidsNrrPMLimerick Resource RidsNrrDorlLpl3 Resource RidsNrrPMNineMilePoint Resource RidsRgn1 MailCenter Resource RidsNrrPMPeachBottom Resource RidsRgn3MailCenter Resource RidsNrrPMQuadCities Resource RidsNrrLAIBetts Resource RidsNrrPMREGinna Resource RidsNrrLASRohrer Resource RidsNrrPMThreeMilelsland Resource RidsAcrs_MailCTR Resource RidsNrrPMExelon Resource RidsNrrPMBraidwood Resource TWertz, NRR RidsNrrPMByron Resource LBurkhart, EDO RidsNrrPMCalvertCliffs Resource JAnderson, NSIR RidsNrrPMClinton Resource MNorris, NSIR RidsNrrPMDresden Resource RKinard, NSIR RidsNrrPMFitzPatrick Resource ADAMS A ccess1on No. M eetmg Not1ce . ML18103A036 M eeting summary ML18120A177 OFFICE NRR/D0RL/LPL3/PM NRR/D0RL/LPL3/LA NRR/D0RL/LPL3/BC NRR/D0RL/LPL3/PM NAME BPurnell SRohrer DWrona BPurnell DATE 4/30/18 4/30/18 5/1/18 5/1/18 OFFICIAL RECORD COPY