ML18305B270

Response to Request for Additional Information - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements

ML18305B270
Person / Time
Site:	Peach Bottom, Limerick
Issue date:	11/01/2018
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML18305B270 (10)

Text

Exelon Generation . 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp com 10 CFR 50.90 November 1, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352. 50-353. and 72-65 Peach Bottom Atomic Power Station, Units 1, 2, and 3 Facility Operating [Possession Only] License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171. 50-277, 50-278 and 72-79

Subject:

Response to Request for Additional Information - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements

References:

1) Letter from James Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements, dated May 10, 2018 (ML18149A290)

2) Electronic Mail Request from Blake Purnell (U.S. Nuclear Regulatory Commission) to Richard Gropp, et al. (Exelon Generation Company, LLC) -

Exelon Generation Company, LLC - Request for Additional Information Regarding License Amendment Request to Revise Emergency Plan for Limerick and Peach Bottom (EPID L-2018-LLA-0150), dated October 2, 2018 (ML18276A020)

By letter dated May 10, 2018 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAA) to support changes to the Emergency Plans for the facilities listed in order to revise certain Emergency Response Organization (ERO) positions with the minimum staff ERO guidance specified in the "Alternative Guidance for Licensee Emergency Response Organizations," finalized in a letter from the NRC to NEI, dated June 12, 2018. The guidance will be included in Revision 2 of NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

U.S. Nuclear Regulatory Commission License Amendment Request Response to Request for Additional Information Changes to Emergency Plan Staffing November 1, 2018 Page2 In a U.S. Nuclear Regulatory Commission (NRC) electronic mail message dated October 2, 2018 (Reference 2), the NRC issued a Request for Additional Information (RAI) indicating that it had reviewed the information submitted in the Reference 1 letter pertaining to the proposed LAR and additional clarifying information was needed in order to support its continued review. The NRC requested that Exelon respond within 30 days of the date of the electronic mail message. The NRC had previously issued a draft RAI via electronic mail message on September 27, 2018, and provided an opportunity for a clarification call to further discuss the RAI. Exelon determined that a clarification call was unnecessary, and the NRC was informed accordingly.

Accordingly, Attachment 1 provides Exelon's response to the RAI contained in Reference 2.

Exelon has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in the Reference 1 submittal. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the State of Pennsylvania of this RAI response by transmitting a copy of this letter and the supporting attachments to the designated State Official.

The Reference 1 submittal included a regulatory commitment regarding performance of a drill. of the letter updates this commitment to reflect the changes proposed in this RAI response.

If you have any questions concerning this submittal, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1st day of November 2018.

Respectfully, David P. Helker Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

1) Response to Request for Additional Information - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements

2) Updated Summary of Regulatory Commitments

U.S. Nuclear Regulatory Commission License Amendment Request Response to Request for Additional Information Changes to Emergency Plan Staffing November 1, 2018 Page 3 cc: w/ Attachment Regional Administrator - NRC Region I NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRA - Peach Bottom Atomic Power Station Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection R. R. Janati, Pennsylvania Bureau of Radiation Protection D. A. Tancabel, State of Maryland

ATTACHMENT 1 Response to Request for Additional Information -

License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements Limerick Generating Station, Units 1 and 2 NRC Docket Nos. 50-352, 50-353, and 72-65 Peach Bottom Atomic Power Station, Units 1, 2, and 3 NRC Docket Nos. 50-171. 50-277, 50-278 and 72-79 Emergency Plan Staffing Changes Response to Request for Additional Information Page 1 of 4 Response to Request for Additional Information - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements By letter dated May 10, 2018 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAA) to support changes to the Emergency Plans for the facilities listed in order to revise certain Emergency Response Organization (ERO) positions with the minimum staff ERO guidance specified in the "Alternative Guidance for Licensee Emergency Response Organizations," finalized in a letter from the NRC to NEI, dated June 12, 2018. The guidance will be included in Revision 2 of NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

In a U.S. Nuclear Regulatory Commission (NRC) electronic mail message dated September 27, 2018 (Reference 2), the NRC issued a draft Request for Additional Information (RAI) indicating that it had reviewed the information submitted in the Reference 1 letter and additional clarifying information was needed to support its continued review. This electronic mail message contained draft questions regarding information provided in Reference 1 and Exelon was provided an opportunity for a clarification call to further discuss the RAI. Exelon determined that a clarification call was unnecessary, and the NRC was informed accordingly.

Subsequently, in an NRC electronic mail message dated October 2, 2018 (Reference 3), the NRC formally issued the RAI and requested that Exelon respond within 30 days of the date of the electronic mail message.

Accordingly, this attachment contains Exelon's response to the Reference 3 RAI. The specific questions included in the Reference 3 electronic mail message are restated below followed by Exelon's response.

Background

Enclosures 1 and 2 of the application provided separate evaluations of the proposed changes for each site. Section 2.4 of each enclosure states, in part:

Those ERO positions designated as Minimum Staffing in the [site] Emergency Plan are those required to activate their respective Emergency Response Facility (ERF). Specifically, these are the ERO positions that are the absolute minimum needed to implement the Emergency Plan (i.e., if any position or function is not staffed then the Emergency Plan may not be effectively implemented).

The planning standard in paragraph 50.47(b)(14) of Title 10 of the Code of Federal Regulations states:

"Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected." Section N, "Drill and Exercise Program," of EP-AA-1000, "Exelon Nuclear Standardized Radiological Emergency Plan," Revision 29 (ADAMS Package Accession No. ML18065A168), states that the Drill and Exercise Program will be used to develop, maintain, and evaluate the capabilities of the ERO to respond to emergency conditions and safeguard the health and safety of station personnel and the general public. However, this plan does not address whether these periodic drills or exercises will be used on a continuing basis Emergency Plan Staffing Changes Response to Request for Additional Information Page 2 of 4 to specifically evaluate the adequacy of the minimum staffing levels to ensure that they continue to retain the necessary key skills to perform required major functions prior to full augmentation.

Exelon has also submitted similar LARs to change the ERO staffing requirements for its facilities in Illinois, New York, and Maryland (ADAMS Accession Nos. ML18053A159 (package) and ML18249A096). In its July 27, 2018, supplement for its LAR to revise the ERO staffing for its facilities in Illinois (ADAMS Accession No. ML18208A405), Exelon stated (emphasis added):

Exelon will institute a "Minimum Staff" drill to be conducted once per drill cycle. The drill will include participation from the Minimum Staff of the Emergency Operations Facility (EOF), the Joint Information Center (JIG), the Technical Support Center (TSC), and the Operations Support Center (OSC) from one of the affected Exelon stations which have implemented the approved ERO staffing changes license amendment. This will allow Exelon to periodically demonstrate that the Standardized Emergency Plan is effectively implemented to perform the required Emergency Preparedness [EP] functions utilizing only the Minimum Staff defined in the Emergency Plan. Since the ERO Minimum Staff is the same for each station under the Exelon Standardized Emergency Plan, it is not necessary to perform the drill for each station in a drill cycle.

Exelon has several EOFs throughout its fleets, some of which serve multiple sites. The consolidated EOFs include a facility in Coatesville, Pennsylvania, that currently serves LGS, PBAPS, and Three Mile Island Nuclear Station, and a facility in Warrenville, Illinois, that serves all of Exelon's facilities in Illinois.

Request A. Describe how Exelon plans to specifically evaluate the adequacy of the minimum staffing levels to perform required functions until full augmentation, with the proposed ERO staffing changes, to ensure continued effective implementation of the respective emergency plans for each site.

Response to RAl-1 A The minimum staffing drill will be evaluated in accordance with Exelon's Drill and Exercise Program and be conducted similarly to those drills described in Section IV.G of the NSIR/DPR-ISG-01, "Emergency Planning for Nuclear Power Plants." The drill will demonstrate the key skills of response organizations to adequately respond to an incident scenario such that the major elements of the plans and preparedness organizations are tested. Applicable Facility Objectives and Demonstration Criteria will be selected for each Emergency Response Facility based on the assigned EP functions. The drill will be critiqued in accordance with Exelon's Drill and Exercise program. The drill may not necessarily be evaluated under the Drill/Exercise Performance (DEP)

Indicator under NEI 99-02, "Regulatory Assessment Performance Indicator Guideline."

B. Describe whether Exelon plans to conduct a "Minimum Staff' drill once per drill cycle from its EOF facility in Coatesville, Pennsylvania, with one of the applicable stations it supports (currently, LGS or PBAPS). Clarify whether or not "Minimum Staff" drills conducted at other EOFs would be credited for LGS and PBAPS. Clarify whether or not the statement above from Exelon's July 27, 2018, supplement for the LAR for its Illinois plants is also intended to apply to the May 10, 2018, LAR for LGS and PBAPS.

Emergency Plan Staffing Changes Response to Request for Additional Information Page 3 of 4 Response to RAl-1 B Exelon will institute the Minimum Staff Drill as part of the drill cycle for its nuclear stations. The drill will include participation from the Minimum Staff of the Emergency Operations Facility (EOF), the Joint Information Center (JIC), the Technical Support Center (TSC), and the Operations Support Center (OSC). The MCR may be represented through use of the Simulator or a drill control cell.

Exelon will perform a Minimum Staff Drill for each Emergency Operations Facility once per drill cycle. Specifically, one site which utilizes the EOF will perform the drill and the other sites which share the EOF will take credit for the performance for that drill cycle. For example, if Limerick performs the Minimum Staff drill for the first drill cycle, then PBAPS would be able to take credit, but Exelon stations in Illinois or New York would not be able to credit the drill.

Attachment 2 of this letter captures the committed actions described in response to Items A and B above.

Section 2.4 of Enclosure 1 and 2 to the LAR states, in part:

As part of the implementation of these changes, a confirmation of the capabilities of the final Minimum Staff personnel will be performed through an EP drill to demonstrate that no loss of function will result due to the changes in the ERO. The corresponding State(s) are invited to participate in this EP drill. Additionally, the NRG will be invited to observe the drill.

Confirm that the Federal Emergency Management Agency would also be invited to observe the drill, or explain why an invitation is not needed.

Response to RAl-2 Exelon hereby confirms that the Federal Emergency Management Agency (FEMA) will also be invited to observe the demonstration drills.

References

1. Letter from James Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements, dated May 10, 2018 (ML18149A290)

2. Electronic Mail Request from Blake Purnell (U.S. Nuclear Regulatory Commission) to Richard Gropp, et al. (Exelon Generation Company, LLC) - Draft RAI for Exelon LAR to Revise ERO Staffing at Limerick and Peach Bottom, dated September 27, 2018

3. Electronic Mail Request from Blake Purnell (U.S. Nuclear Regulatory Commission) to Richard Gropp, et al. (Exelon Generation Company, LLC)- Exelon Generation Company, LLC - Request for Additional Information Regarding License Amendment Request to Revise Emergency Plan for Limerick and Peach Bottom (EPID L-2018-LLA-0150), dated October 2, 2018 (ML18276A020)

4. Meeting Summary from the U.S. Nuclear Regulatory Commission, May 1, 2018 - Summary of April 26, 2018, Meeting with Exelon Generation Company, LLC Regarding Draft Guidance for Emergency Response Organization Staffing (EPID L-2018-LRM-0028) (ML18120A177)

Emergency Plan Staffing Changes Response to Request for Additional Information Page 4 of 4

5. Letter from the U.S. Nuclear Regulatory Commission to the Nuclear Energy Institute (NEI) -

Alternative Guidance for Licensee Emergency Response Organizations, dated June 12, 2018.

(ML18022A352)

ATTACHMENT 2 Updated Summary of Regulatory Commitments Updated Summary of Regulatory Commitments Page 1of1 UPDATED

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITMENT TYPE COMMITTED ACTION OR COMMITMENT One-Time Programmatic "OUTAGE" Action (Yes/No) (Yes/No)

Exelon will conduct a confirmation Prior to implementation of Yes No Emergency Preparedness Drill at one of approved license the affected Pennsylvania stations amendment.

(Limerick or Peach Bottom) under this License Amendment Request to demonstrate that no loss of EP function will result due to the proposed changes in the ERO. The drill will include each of the Emergency Response Facilities described in the Emergency Plan (i.e.,

MCR, TSC, OSC, EOF and JIC).

Exelon will institute a Minimum Staff Drill During station drill cycles. No Yes as part of the drill cycle for its nuclear stations. The drill will include participation from the Minimum Staff of the Emergency Operations Facility (EOF), the Joint Information Center (JIC), the Technical Support Center (TSC), and the Operations Support Center (OSC). The MCR may be represented through use of the Simulator or a drill control cell. The minimum staffing drills will be evaluated in accordance with Exelon's Drill and Exercise Program. The drill will demonstrate the key skills of response organizations to adequately respond to an incident scenario such that the major elements of the plans and preparedness organizations are tested. The drill will be critiqued in accordance with Exelon's Drill and Exercise program. The drill may not necessarily be evaluated under the Drill/Exercise Performance (DEP)

Indicator under NEI 99-02, Regulatory Assessment Performance Indicator Guideline. Note that for stations which share an EOF, a station may credit performance of a minimum staff drill through another station which shares the EOF facility.