ML19053A558

Federal Emergency Management Agency Review Requested of Revision to the Davis-Besse Nuclear Power Station Emergency Plan for Post-Shutdown and Permanently Defueled Condition

ML19053A558
Person / Time
Site:	Davis Besse
Issue date:	03/07/2019
From:	James Anderson Office of Nuclear Security and Incident Response
To:	Quinn V Federal Emergency Management Agency, Area 8
Joseph Anderson
References
Download: ML19053A558 (4)

Text

March 7, 2019 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 DAVIS-BESSE NUCLEAR POWER STATION EMERGENCY PLAN FOR POST-SHUTDOWN AND PERMANENTLY DEFUELED CONDITION

Dear Ms. Quinn:

By letter dated April 25, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18115A007), FirstEnergy Nuclear Operating Company (FENOC) certified to the U.S. Nuclear Regulatory Commission (NRC), pursuant to Sections 50.82(a)(1)(i) and 50.4(b)(8) of Title 10 to the Code of Federal Regulations (10 CFR), of its intention to permanently cease power operations at the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS) by May 31, 2020. In preparation for the permanent cessation of operations at DBNPS, by letter dated February 5, 2019 (ADAMS Accession No. ML19036A524), FENOC submitted for prior NRC approval, a license amendment request (LAR) to the DBNPS Emergency Plan. Refer to URL below to access the LAR submittal.

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19036A524 The proposed changes to the DBNPS Emergency Plan, hereafter referred to as the DBNPS Post-Shutdown Emergency Plan (PSEP), would revise the licensees on-shift and augmented emergency response organization (ERO) staffing in support of the post-shutdown and permanently defueled condition of DBNPS. 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 subsequent 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.

Pursuant to 10 CFR 50.82(a)(i) and (ii), implementation of the proposed DBNPS PSEP would not occur until after FENOC certifies in writing to the NRC that the reactor has permanently ceased operations and fuel has been permanently removed from the reactor vessel. Upon docketing of these certifications, the 10 CFR Part 50 license for DBNPS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel.

V. Quinn Section 4.6 of Enclosure A, Evaluation of a Request for Licensing Action, to FENOCs February 5, 2019, submittal provides the licensees assessment of the proposed staffing changes on offsite response organization interfaces. Based on the results of this assessment, FENOC concluded the following:

In summary, no coordination or communication impediments, with the offsite response organizations were identified by the proposed changes to the DBNPS ERO. As a result, there should be no impact on the ability of the State and County response organizations to implement their FEMA-approved radiological emergency plans.

The NRCs preliminary review of the proposed DBNPS PSEP 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 the existing FEMA-approved State and local radiological emergency response plans and procedures.

FENOC is requesting NRC approval of the proposed DBNPS PSEP by January 31, 2020.

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 May 8, 2019, to support any further request for additional information to FENOC, as needed to support the NRCs continued technical review and final determination, and completion and issuance of the safety evaluation report approving the licensing action.

To facilitate FEMAs assessment, in Enclosure B, State and County Reviews, to its February 5, 2019, submittal, FENOC enclosed letters from the State of Ohio, Lucas County and Ottawa County Emergency Management Agencyies, which document their discussions with FENOC concerning the proposed DBNPS PSEP and their satisfaction that these changes will not impact the ability to effectively implement their FEMA-approved radiological emergency preparedness (REP) plans.

In addition, Attachment 5, List of Regulatory Commitments, to Enclosure A of FENOCs February 5, 2019, submittal states that prior to implementation of the proposed DBNP PSEP:

To validate the results of the proposed changes to the ERO described within this amendment request, FENOC will perform a drill to confirm the ability of the Post Shutdown on-shift and augmented emergency response organization 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. The drill will evaluate the ability to accomplish the stated mission of each ERF and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. State and local response organizations will be provided the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities.

V. Quinn As always, thank you for your assistance. If you have any questions regarding the changes proposed in the DBNPS PSEP, the NRCs evaluation of these proposed changes, or if FEMA will be unable to meet the requested due date of May 8, 2019, 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 S. OLeary, FEMA Region V

V. Quinn

SUBJECT:

FEDERAL EMERGENCY MANAGEMENT AGENCY REVIEW REQUESTED OF REVISION TO THE DAVIS-BESSE NUCLEAR POWER STATION EMERGENCY PLAN FOR POST-SHUTDOWN AND PERMANENTLY DEFUELED CONDITION DATED: 03/07/19 DISTRIBUTION:

J.D. Anderson, NSIR M. Norris, NSIR R. Kinard, NSIR A. Barker, Region III H. Logaras, Region III R. Baker, Region III C. Wolf, OCA ADAMS Accession Number: ML19053A558 OFFICE NSIR/DPR NSIR/DPR:TL NSIR/DPR: BC NAME R. Kinard M. Norris J. D. Anderson DATE 02/15/19 03/07/19 03/07/19 OFFICIAL RECORD COPY