ML21033A537

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Email transmission- 01-29-2021, FEMA Letter to Governor of Commonwealth of PA Regarding Implementation of TMI EP Exemptions
ML21033A537
Person / Time
Site: Dresden, Byron  Constellation icon.png
Issue date: 02/01/2021
From: James Anderson
NRC/NSIR/DPR/RLB
To: Nancy Salgado
NRC/NRR/DORL/LPL3
Anderson J
Shared Package
ML21033A555 List:
References
Download: ML21033A537 (3)


Text

From: Anderson, Joseph To: Salgado, Nancy Cc: Wiebe, Joel; norris, michael; Mott, Kenneth; Page, Hayden; Haskell, Russell

Subject:

RAIs: Byron/Dresden Decommissioning Emergency Plan LARs (L-2020-LLA-0237 & 0240)

Date: Monday, February 01, 2021 2:19:00 PM LICENSE AMENDMENT REQUEST RELATED TO PROPOSED EMERGENCY PLAN CHANGES FOR THE EXELON GENERATION COMPANY, LLC BYRON STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-454 AND 50-455 DRESDEN NUCLEAR POWER STATION, UNIT NOS. 1, 2 AND 3 DOCKET NOS. 50-10, 50-237 AND 50-249 By application dated November 2, 2020 ((Agencywide Documents Access and Management System (ADAMS) Accession No. ML20307A333 and ML20307A433

[package]), Exelon Generation Company, LLC (Exelon) requested approval by the U.S.

Nuclear Regulatory Commission of proposed changes to the for the Byron Station Units 1 and 2 (Byron) and Dresden Nuclear Power Station Units 1, 2 and 3 (Dresden) Site Emergency Plan (SEPs) to support the planned permanent cessation of operations and permanent defueling of the respective reactors. The proposed changes would revise the on-shift and augmented emergency response organization (ERO) staffing commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled nuclear power reactor facilities.

The following requests for additional information (RAIs) to facilitate the technical review being conducted by the Division of Preparedness and Response, Operating Reactor Licensing and Outreach Branch staff. Timely and accurate response to these draft RAIs is requested.

RAI-1

Requirement:

10 CFR 50.47(b)(1) requires that each principal response organization has staff to respond and to augment its initial response on a continuous basis.

10 CFR 50.47(b)(2) requires that the on-shift facility licensee has adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities is available.

10 CFR 50.47(b)(9) requires that the on-shift facility licensee has adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion B.1.a states that the site-specific ERO is developed.

Issue: Section 5.3.5, Emergency Preparedness Function: Dose Assessment / Projections, of Attachment 1, [site-specific] Description and Evaluation of Proposed Changes, states:

The analysis of proposed post-shutdown On-Shift Staffing Assessment concluded that in a permanently defueled condition, the Operations crew can perform all required [site specific] Emergency Plan actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions.

Request: Pease clarify if the on-shift operations personnel are members of the Fire Brigade, and if so, who would perform assessment of radiological releases during a fire involving radioactive material or in areas containing radioactive materials requiring a Fire Brigade response? Additionally, please clarify if the on-shift operations personnel have actions to perform for implementation the site-specific spent fuel pool mitigation strategies, and if so, does this create a collateral duty that would prevent the timely performance of emergency plan functions (e.g., dose assessment)?

RAI-2

Requirement:

10 CFR 50.47(b)(1) requires that each principal response organization has staff to respond and to augment its initial response on a continuous basis.

10 CFR 50.47(b)(2) requires that the on-shift facility licensee has adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities is available.

Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion B.1.a states that the site-specific ERO is developed.

Issue: Section B.3.9, OSC [Operations Support Center] RP [Radiation Protection] Lead, of , [site-specific] Proposed Revision to Site Emergency Plan, provides the responsibilities for the managing and supervising OSC team RP personnel, including:

Conduct of adequate pre-dispatch briefings; Ensuring adequate protective equipment and measures have been identified; Tracking of OSC team activities while dispatched, and Debriefing of team personnel upon return to the OSC.

However, Section 5.3.10, Emergency Preparedness Function: Supervision of Repair Team Activities, of Attachment 1 states:

(1) Radiation Protection Supervisor / Lead1 Note 1. Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

Additionally, Figure B-1b, Emergency Response Organization, of Attachment 3 states:

1 Rad Protection Lead responsibilities will be performed by a Rad[iation] Protection

Pool responder as a collateral function.

Further, item #95 of Attachment 4, Emergency Response Organization Task Analysis, states the following for justification/implementing action:

The duties for oversight of the RP OSC staff wlll be taken as a collateral function for a RP Technician.

Request: Pease clarify why the OSC RP Lead position is included since it is a collateral function of another augmenting responder. Additionally, are the RP Technicians trained and qualified to perform these identified functions?

If you have any questions regarding the RAIs above or if licensee requests a conference call to discuss, please contact either Kenneth Mott or Michael Norris.

Joseph D. Anderson Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission (301) 287-9300 joseph.anderson@nrc.gov