ML18324A404
| ML18324A404 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 11/20/2018 |
| From: | David Helker Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TM-18-103 | |
| Download: ML18324A404 (10) | |
Text
200 Exelon Way Exelon Generation Kennett Square, PA 19348 10 CFR 50.90 TM-18-103 November 20, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Possession Only License No. DPR-73 NRC Docket No. 50-320
Subject:
Supplemental Information Regarding License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Post-Shutdown and Permanently Defueled Condition
Reference:
- 1) Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "License Amendment Request -
Proposed Changes to the Three Mile Island Emergency Plan for Post-Shutdown and Permanently Defueled Condition," dated March 19, 2018, TM-18-038 (ML18078A578)
- 2) Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Response to Request for Additional Information (RA/) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Post-Shutdown and Permanently Defue/ed Condition" dated August 13, 2018 (ML18225A180)
By letter dated March 19, 2018 (Reference 1), and as supplemented in a letter dated August 13, 2018 (Reference 2), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAR) for changes to the site emergency plan (SEP) for the Three Mile Island Nuclear Station (TMI). The proposed amendment would revise the SEP to change the staffing for certain emergency response organization (ERO) positions for the post shutdown and permanently defueled condition.
Based on a telephone discussion between the U.S. Nuclear Regulatory Commission (NRC) and Exelon on November 14, 2018, the NRC identified an inconsistency regarding the description of two ERO positions in the Emergency Operations Facility (EOF) proposed to be removed from the SEP. Exelon is providing supplemental information to clarify the inconsistency in the LAR (Reference 1), as supplemented in Reference 2.
U.S. Nuclear Regulatory Commission Supplemental Information to TMI License Amendment Request Docket Nos. 50-289 and 50-320 November 20, 2018 Page2 Exelon is providing information to supplement the LAA in the Attachment to this submittal. The changes submitted in the Attachment to this letter supersede in its entirety the corresponding sections identified in Reference 1, Attachments 1, 2, and 4.
Exelon has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the previously stated bases in Reference 1 for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the 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.
TMI, Unit 2, has a possession only license and is currently maintained in accordance with the NRC approved SAFSTOR condition {method in which a nuclear facility is placed and maintained in a condition that allows it to be safely stored and subsequently de-contaminated) known as Post-Defueling Monitored Storage. Exelon maintains the emergency planning responsibilities for TMI, Unit 2, which is owned by First Energy Corporation, through a service agreement.
If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 201h day of November 2018.
Respectfully, David P. Helker Manager, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Supplemental Information Regarding License Amendment Request -
Proposed Changes to the Three Mile Island Emergency Plan for Post-Shutdown and Permanently Defueled Condition cc: w/Attachments NRC Regional Administrator, Region I NRC Senior Resident Inspector- Three Mile Island Nuclear Station - Unit 1 NRC Project Manager, NRR - Three Mile Island Nuclear Station - Unit 1 NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island - Unit 2 Director, Bureau of Radiation Protection - PA Department of Environmental Protection
Attachment Supplemental Information Regarding License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Post-Shutdown and Permanently Defueled Condition
Attachment Supplemental Information to TMI License Amendment Request Docket Nos. 50-289 and 50-320 Page A-1 of A-7
SUMMARY
By letter dated March 19, 2018 (Reference 1), and as supplemented in a letter dated August 13, 2018 (Reference 2), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAA) for changes to the site emergency plan (SEP) for the Three Mile Island Nuclear Station (TMI). The proposed amendment would revise the SEP to change the staffing for certain emergency response organization (ERO) positions for the post-shutdown and permanently defueled condition.
Based on a telephone discussion between the U.S. Nuclear Regulatory Commission (NRC) and Exelon on November 14, 2018, the NRC identified an inconsistency regarding the description of two ERO positions in the Emergency Operations Facility (EOF) proposed to be removed from the SEP. Specifically, Table 2-2 of Attachment 1 of Reference 1 stated that the Operations Advisor and the Operations Assistant positions were to be removed from the SEP and designated full augmentation and controlled via emergency preparedness implementing procedures (EPIP).
However, Section 5.2.5.c of Attachment 1 of Reference 1 stated that the Operations Advisor position was proposed to be eliminated. It was Exelon's intent to eliminate the Operations Assistant position and remove the Operations Advisor position from the SEP and control the Operations Advisor position via the EPIPs.
The Operations Assistant position was added following the relocation of TMl'S EOF to Coatesville to provide TMI specific Operations knowledge in support of the existing Corporate based Technical Support Manager and Operations Advisor positions. With TMI permanently shut down and defueled, the spectrum of credible accidents and operational events no longer require the augmented position; therefore, the Operations Assistant position in the EOF can be eliminated without impacting TMl's ability to respond to an event.
The EOF Operations Advisor reports to the EOF Technical Support Manager and directs the ENS Communicator and is responsible for obtaining and analyzing plant status information. The EOF Operations Advisor position is to be retained as an ERO position. However, considering no essential functions were identified to support Emergency Planning Functions, the EOF Operations Advisor position can be relocated to a full augmentation position and be controlled via EPIPs without impacting TMl's ability to respond to the spectrum of credible accidents and operational events for a permanently shut down and defueled reactor.
Exelon is providing information below to clarify the inconsistency identified by the NRC. Reference 1, Attachment 1, "Description and Evaluation of Proposed Changes", Table 2-2 and Section 5.2.5.c were revised to correct the inconsistency. Also, the section addressing the Operations Advisor position in Reference 1, Attachment 2, "Tabular Summary of Changes to the Three Mile Island Emergency Plan," and Reference 1, Attachment 4, "Three Mile Island ERO Staffing Assessment Matrix," were revised. The changes submitted in this Attachment supersede in its entirety the corresponding sections identified in Reference 1, Attachments 1, 2, and 4.
Attachment Supplemental Information to TMI License Amendment Request Docket Nos. 50-289 and 50-320 Page A-2 of A-7 Reference 1, Attachment 1: Description and Evaluation of Proposed Changes Table 2-2, TMI Augmented Staff Position Disposition Current Auamented Staff Position Proposed Augmented Staff Disposition Technical Support Center (TSC)
Security Coordinator Position designated as minimum staff
(@ 60 min.)
Rad Controls Coordinator Position Eliminated Rad Controls Engineer Position Eliminated TSC Operations Communicator Position Eliminated CR Operations Communicator Position Eliminated CR Damage Control Communicator Position Eliminated State/Local Communicator Position Eliminated Looistics Coordinator Position Eliminated TSC Technical Communicator Position Eliminated TSC Damaqe Control Communicator Position Eliminated HPN Communicator Position Eliminated Clerical Staff Position Eliminated Emergency Operations Facility CEOF)
Technical Suooort Manaqer Desionated Full Auomentation per EPIP Regulatory Liaison Designated Full Augmentation per EPIP Dose Assessor Desionated Full Auomentation per EPIP Operations Advisor Desionated Full Auomentation per EPIP Technical Advisor Designated Full Augmentation per EPIP Computer Specialist Computer Specialist Position designated as minimum staff ( @90 min)
EOF Security Coordinator Desionated Full Auomentation per EPI P EOF Administrative Coordinator Desionated Full Au omentation per EPI P State EOC Liaison Desionated Full Au qmentation per EPI P EOF Clerical Support Designated Full Au gmentation per EPIP Operations Assistant Position Eliminated Field Team Communicator Desionated Full Au omentation per EPIP EOF ENS Communicator Designated Full Augmentation per EPIP EOF Events Recorder Desianated Full Au amentation per EPIP EOC (Governmental) Communicator Desionated Full Auomentation per EPI P N/A HPN Communication designated Full Auomentation per EPIP N/A EOF Director designated Full Augmentation per EPIP N/A Logistics Manager designated Full Augmentation per EPIP N/A Environmental Coordinator designated Full Auomentation per EPIP Joint Information Center CJIC)
JIC Coordinator Designated Full Augmentation per EPIP News Writer DesiQnated Full Augmentation per EPIP
Attachment Supplemental Information to TMI License Amendment Request Docket Nos. 50-289 and 50-320 Page A-3 of A-7 Desi nated Full Au mentation er EPIP Desi nated Full Au mentation er EPIP Desi nated Full Au mentation er EPIP Desi nated Full Au mentation er EPIP Desi nated Full Au mentation er EPIP Desi nated Full Au mentation er EPIP Desi nated Full Au mentation er EPIP Desi nated Full Au mentation er EPIP Position Eliminated Position Eliminated Position Eliminated 5.2.5 Major Functional Area: Plant System Engineering, Repair and Corrective Action
- c. Major Task: Accident Analysis ON-SHIFT There are no requirements for staffing this position for the on-shift staffing.
AUGMENTED ERO Current Requirements The current TMI Emergency Plan has the following Full Augmented staff in the EOF to support the accident analysis function:
- Technical Support Manager
- Operations Advisor
- Operations Assistant
- Technical Advisor Proposed Changes TMI proposes to eliminate the following full augmentation positions:
- Operations Assistant The following full augmentation positions will be removed from the SEP and controlled and managed by EPI Ps:
- Technical Support Manager
- Operations Advisor
- Technical Advisor Analysis The complexity of activities required for safe storage of spent fuel is reduced, as compared to an operating power reactor. Restoration of equipment supporting spent fuel cooling and inventory will be the primary focus of emergency mitigation actions for the TSC/OSC in a permanently shutdown and defueled condition. In addition, the elimination of credible
Attachment Supplemental Information to TMI License Amendment Request Docket Nos. 50-289 and 50-320 Page A-4 of A-7 accidents involving an operating power reactor provides additional time to plan and execute assessment and mitigation actions.
The Operations Assistant position in the EOF is staffed with TMI station personnel with an operations background familiar with the TMI Emergency Operating Procedures and provide support to the EOF Operations Advisor and EOF Tech Support Manager. With permanent cessation of plant operations all EOPs will no longer be applicable, and implementation of the Permanently Shutdown Emergency Plan will only deal with events related to storage of irradiated fuel in the Spent Fuel Pool. Therefore, the Operations Assistant position in the EOF can be eliminated without impacting TMl's ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor.
The EOF Technical Support Manager (TSM) directs the activities of the Technical Support Group. A review of major functions of the Technical Support Manager is provided in Attachment 4, and the function to provide information to the State and Local Communicator for completing the state/local notification form is assigned to the Corporate Emergency Director. No essential functions were identified to support Emergency Planning Functions. Therefore, the TSM can be relocated to a full augmentation position and be controlled via EPIPs without impacting TMl's ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor.
The EOF Operations Advisor reports to the EOF Technical Support Manager and directs the ENS Communicator and is responsible for obtaining and analyzing plant status information. The ENS communications will remain with the TSC and the EOF ENS communicator position is being maintained as a backup to the TSC ENS communicator.
A review of the major functions of the EOF Operations Advisor were reviewed and documented in Attachment 4. No essential functions were identified to support Emergency Planning Functions. Therefore, the EOF Operations Advisor can be relocated to a full augmentation position and be controlled via EPIPs without impacting TMl's ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor.
The Technical Advisor position in the EOF provides support to other positions in the EOF.
As shown in Attachment 4, there were no essential task required for support of Emergency Planning Functions. The Technical Advisor position in the EOF can be removed from the SEP and relocated to EPIPs without impacting TMl's ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor.
The full augmentation positions will still be assigned to ERO teams, be expected to maintain Fitness-for-Duty during assigned duty weeks, and are required to respond to the EOF at an Alert or higher classification.
Implementation of these changes do not impact the overall effectiveness to perform the necessary Emergency Planning Functions and will not cause undue impact to the performance of the TMI Emergency Plan.
Attachment Supplemental Information to TMI License Amendment Request Docket Nos. 50-289 and 50-320 Page A-5 of A-7 Reference 1, Attachment 2: Tabular Summary of Changes to Three Mile Island Emergency Plan Emergency Plan Current Wording Proposed Wording Reason for Change Section EP-TM-1000 5) Ogerations Advisor EOF 6} GsaratiaRs Am1J6aF eGF The Operations Advisor position is being made a Part II Section B 5.b. The Operations Advisor reports to the Technical Support 'The GperatiaRs AdvisaF- fBPBFIB te tRe -:fBGRRiGal S1:1ppaFt full augmentation position Manager, directs the ENS Communicator, and is MaRageF-, fliFBGts tRe eAJS G91RFRl:IRiGateF, aREJ 1"6 Corporate ERO not required to activate the responsible for obtaining and analyzing plant status Fe6f3aRs,iela ta,- 913taiRiRg aREJ aRa/yaRg plaRt staU:16 EOF. The Operations
- 5. Operations Advisor information and ensuring that it is disseminated. Specific iRfaFmatiaR aREl eRSl:IFiRg that it i6 dissemiRateEJ. SpeGifis Advisor will be removed responsibilities include: ffJSpBRSib#itias iRG!iJdfJ:
from the SEP and will be
- Monitor the Operations Status Line to keep apprised
- MeRiteF tRe GperatiaRs StaU:16 l:iRe te keep apprised managed and controlled of: et; by EPIPs.
- Control Room activities including progress on GaRt."6! fiaam aGtivities iRGludiR§J pfeg,"666 BR This revision is further Emergency Operating Procedures. EFRBfJBRGy- (;)peFatiRg PfaGefil:l,<es. discussed in Attachment 1, Section 5.2.5,
- Significant changes in plant system/equipment SigRifiGaRf GRBRgBS iR plaRt 6}'6feFRl9ffl:/ipFRBRt Evaluation of Proposed status and critical parameters. staU:16 aRfi GritiGal paFaFR8teF6.
Changes.
- Possible changes in event classification. ,"-as6iele GhaRgBS iR 8V8Rt GlassifiGatiaR.
Evaluation of this ERO
- Identify and track critical parameters for the
- hiaRtify- aREl tFaGk Griti6al paFaFR8teF6 faF tRe position's responsibilities identification and trending of current plant status idaRtifiGatiaR aRfi t.<eREJiRg al Gl:lfF8Rt plaRt staU:16 is performed in information. ,iRfaFFRatiaR. Attachment 4, ERO Task Analysis, including an
- Assist the station in identifying Operations
- A6&i.st tRa statiaR iR idaRtify-iRg GperatiaRs FBS91:1'6BS evaluation of which resources from corporate staff or unaffected stations fl:em G9Ff}91'afe sta# 9F l:IRaffeGted statiaRS faf- EJiHJGt responsibilities can be for direct support of plant shift operations personnel. s1:1ppaFt alplaRt shift ape;atiaRs persaRRe!.
deleted and which can be
- Assist the ENS Communicator in the completion of
- Assi6t tRe e-.~JS Gamm1:1RiGateF- iR tRe GamptetiaR af reassigned.
the NRG Event Notification Worksheet and in tRa A.ffiG e-VBRt A.t.atifiGatiGR We;k6haet aREl iR responding to NRG inquiries. FespaREiiRg te !>,ffiG iRq1:1iries.
- Ensure that the EOF Radiation Protection Manager
- eRSl:l/6 tRat tRe ~ RafiiatiaR f2.."6teGtiaR MaRagBF ,i.s is informed of changes in plant status that impact or iRfaffReEl al GhaRges iR plaRt staU:16 tRat impaGt ar potentially impact the offsite environment or PARs. pateRtially- impaGt tRa affsite 8RVH'8RFR8Rt 91'- /2Afis.
Attachment Supplemental Information to TMI License Amendment Request Docket Nos. 50-289 and 50-320 Page A-6 of A-7 Reference 1, Attachment 4: THREE MILE ISLAND ERO STAFFING ASSESSMENT MATRIX Tasks Task transferred NRC Disposition to this Current Pl Tasks defined by Station Emergency Plan (Eliminated/ position per E-Plan ERO Position Min Key ('E-' are E plan and 'P-' are procedure Reassigned Justification / this Section Facility Position Eliminated Staff ERO tasks) To) Implementing action Assessment Reference EOF Operations No No E-EOA 1 - Monitor the Operations Status Line Eliminate These are Support EP-TMI-Advisor Relocated to keep apprised of: Control Room activities activities, not required for 1000, Part EOA to EPIP including progress on Emergency Operating performance of II, Section Procedures; Significant changes in plant Emergency Planning 8.5.b.5 system/equipment status and critical Functions. Position is I
parameters: Possible changes in event removed from SEP and is classification managed and controlled E-EOA2 - Identify and track critical Eliminate by EPIPs.
parameters for the identification and trending of current plant status information.
E-EOA3 - Assist the station in identifying Eliminate Operations resources from corporate staff or unaffected stations for direct support of plant shift operations personnel.
E-EOA4 - Assist the ENS Communicator in Eliminate the completion of the NRC Event Notification Worksheet and in responding to NRC inquiries.
E-EOA5 - Ensure that the EOF Radiation Eliminate Protection Manager is informed of changes I in plant status that impact or potentially impact the offsite environment or PARs.
Attachment Supplemental Information to TMI License Amendment Request Docket Nos. 50-289 and 50-320 Page A-7 of A-7 References
- 1) Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Post-Shutdown and Permanently Defueled Condition," dated March 19, 2018, TM-18-038 (ML18078A578)
- 2) Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Post-Shutdown and Permanently Defueled Condition" dated August 13, 2018 (ML18225A180)