PLA-6937, Response to Request for Supplemental Information to Support Acceptance of Exemption Request from the Biennial Emergency Preparedness Exercise Requirements of 10 CFR 50, Appendix E, Section IV.F.2.b
| ML12324A249 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/16/2012 |
| From: | Helsel J Susquehanna |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PLA-6937 | |
| Download: ML12324A249 (8) | |
Text
Jeffrey M. Helsel PPL Susquehanna, LLC \ I I
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\ l I I I Plant Manager 769 Salem Boulevard '\llfl ~
Berwick, P A 18603 ~~ * * * * * * * ~' #'
Tel. 570.542.3510 Fax 570.542.1504 U. S. Nuclear Regulatory Commission jmhelsel @pplweb.com Pp .. .l==: ~ ',
~, TM Attn: Document Control Desk Washington, D.C. 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR SUPPLEMENTAL INFORMATION TO SUPPORT ACCEPTANCE OF EXEMPTION REQUEST FROM THE BIENNIAL EMERGENCY PREPAREDNESS EXERCISE REQUIREMENTS OF 10 CFR 50, APPENDIX E, SECTION IV.F.2.b Docket Nos. 50-387 PLA-6937 and 50-388
References:
- 1) Letter, J. Whited (NRC) toT. Rausch (PPL), "Supplemental Information Needed for Acceptance of Requested Licensing Action Re: Exemption Request from the Biennial Emergency Preparedness Exercise Requirements of 10 CFR 50, Appendix E, Section N.F.2.b (TAC Nos. ME9845 and ME9846)," dated November 6, 2012.
- 2) PLA-6922, T. Rausch (PPL) to Document Control Desk (NRC), "Exemption Request from the Biennial Emergency Preparedness Exercise Requirements of 10 CFR, Appendix E,Section IV.F.2.b," dated October 25, 2012. (ML12300A108)
- 3) NRC Regulatory Issue Summary 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements," dated February 24, 2006.
PPL Susquehanna, LLC (PPL) requested in Reference 2, a one-time exemption from the requirements of 10 CPR 50, Appendix E,Section IV.F.2.b to reschedule the evaluation of the onsite elements of the Susquehanna Steam Electric Station's (SSES's) biennial Emergency Preparedness exercise from October 23, 2012 to February 26, 2013. After review of this request, the NRC identified the need for PPL to provide supplemental information in a November 6, 2012letter to PPL (Reference 1). The Attachment to this letter provides PPL's response to the requested information.
If you have any questions regarding this letter, please contact Mr. John L. Tripoli, Manager, Nuclear Regulatory Affairs, at (570) 542-3100.
letter contains no new regulatory commitments.
Attachment
Document Control Desk PLA-6937 Copy: Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. J. Whited, NRC Project Manager Mr. L. Winker, PA DEP/BRP Administrator, NRC Region I
Attachment to PLA-6937 Supplemental Information to Support NRC Acceptance of PPL's Exemption Request from the Onsite Portion of the Biennial Emergency Preparedness Exercise Requirements -10 CFR 50, Appendix E,Section IV.F.2.b
Attachment to PLA-6937 Page 1 of 5 Supplemental Information to Support NRC Acceptance of PPL's Exemption Request from the Onsite Portion of the Biennial Emergency Preparedness Exercise Requirements -10 CFR 50, Appendix E,Section IV.F.2.b NRC Question 1:
Page 1 of the attachment states, A one-time change in the exercise schedule increases the interval between biennial exercises, but in most cases the postponed exercise still falls within the 35 month window thus meeting the intent of the regulation cited in the [regulatory issue summary] RIS.
It is unclear to the NRC staff whether this is a statement, or this is citing Section 50.12(a)(2) special circumstances criterion (ii) which states, "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule."
PPL Response to Question 1:
The italicized text above was intended to be a statement from NRC RIS 2006-03.
However, PPL is also citing that 50.12(a)(2), special circumstance criterion (ii) applies to the exemption request (Reference 2). See PPL's response to Question 5 for additional information.
NRC Question 2:
Page 1 of the attachment also states, The Unit 1 shutdown will affect a significant number of employees who will then not be available to support the drill. PPL had planned to deploy approximately 115 players and controllers to conduct the exercise. This includes an operating shift as well as several key managers. During an outage, these individuals are deployed on different shifts and typically are covering 12-hour periods staffing our Outage Control Center and other outage functions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. October 23 was the fourth day of the Unit 1 outage. In addition, SSES Unit 2 is still operating.
Attachment to PLA-6937 Page 2 of 5 Page 2 of the attachment states, Although the conduct of an exercise or drill and associated critiques involves only a limited amount of time, it would be an undue burden during this period of time to manage this activity during the course of an outage.
It is unclear to the NRC staff whether these are statements or if they are citing Section 50.12(a)(2) special circumstances criterion (iii) which states, "Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated."
PPL Response to Question 2:
The italicized text above was intended to be a statement regarding the impact on PPL resources if the onsite portion of the biennial EP exercise was conducted as scheduled.
See PPL' s response to Question 5 for additional information.
NRC Question 3:
Page 2 of the attachment also states, From a risk perspective, PPL believes it is less risk to public health and safety to reschedule the onsite portion of the exercise to February 26, 2013.
It is unclear to the NRC staff whether this is a statement or if this is citing Section 50.12(a)(2) special circumstance criterion (iv) which states, "The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption."
PPL Response to Question 3:
The italicized text above was not intended to cite that Section 50.12(a)(2) special circumstance criterion (iv) applies to the exemption request (Reference 2). See PPL's response to Question 5 for additional information.
Attachment to PLA-6937 Page 3 of5 NRC Question 4:
Page 2 of the attachment also states, This request for an exemption provides only temporary relief since the onsite portion of the exercise will be performed on February 26, 2013. PPL made a good faith effort to comply with the regulation. An extensive amount of planning was peiformed, a challenging scenario was developed, and required submission dates for exercise scenarios were met.
It is unclear to the NRC staff whether this is a statement or if this is citing Section 50.12(a)(2) special circumstance criterion (v) which states, "The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation."
PPL Response to Question 4:
PPL is citing that 50.12(a)(2), special circumstance criterion (v) does apply to the exemption request (Reference 2). See response to Question 5 for additional information.
NRC Question 5:
In order to make the application complete, the NRC staff requests that PPL supplement the application to specifically identify which special circumstances are present in the request. The NRC staff also requests that the basis for the special circumstances be clearly outlined in the supplement.
PPL Response to Question 5:
As discussed in RIS 2006-03, for a typical exercise exemption, two criteria of 10 CFR 50.12(a)(2) are relevant. 10 CFR 50.12(a)(2)(ii) states, "application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." 10 CFR 50.12(a)(2)(v) states, "the exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation."
Also, the RIS states that to accommodate the scheduling of exercises, the NRC has allowed licensees the flexibility to schedule their exercises at any time during the biennial calendar year. This provides a 13 to 35-month window to schedule exercises while still meeting the biennial requirement. A one-time change in the exercise schedule increases the interval between biennial exercises, but in most cases, the postponed exercise still falls within the 35-month window, thus meeting the intent of the regulation.
Attachment to PLA-6937 Page4 of5 PPL has made a good faith effort to comply with the regulation. The biennial exercise was scheduled to be performed on October 23, 2012. However, on September 28, 2012, PPL was notified by its low pressure (LP) turbine supplier about a potential recommendation to conduct a turbine inspection. On October 3, 2012, the supplier provided a formal recommendation to remove the Unit 1 Main Turbine from service prior to October 12, 2012 to perform LP turbine end blade root inspections. PPL reduced power to reduce blade tip vibration on both Unit 1 and Unit 2. This reduction in power allowed additional time for outage planning and Unit 1 was shutdown on October 20, 2012. This required redirection of plant resources, which resulted in rescheduling the onsite portion of the biennial EP exercise. The offsite portion of the biennial exercise, which was coordinated with FEMA and local and state agencies was conducted on October 23, 2012. Due to the unplanned Unit 1 outage, the onsite portion of the biennial exercise (which required activation of the emergency response facilities) was not completed.
PPL personnel supported FEMA, the State of Pennsylvania and local agencies with the offsite portion of the biennial exercise October 23, 2012. PPL established a control cell from the EOF utilizing the FEMA-approved exercise scenario to drive the offsite response. All PPL onsite positions that would provide the communications to I from offsite agencies regarding EAL classifications and Protective Action Recommendations were staffed by control cells comprised of Emergency Planning and Regulatory Affairs staff. In addition, one Recovery Manager who was not assigned an outage duty the day of the drill also participated as a control cell, specifically to address the communications with the Senior State Official. The control cells were all staffed at the EOF and no interaction was planned or occurred at the site during performance of the offsite portion of the evaluated exercise. This was purposely planned to assure that no distraction would be introduced onsite during the discovery phase of the Unit 1 turbine outage. As a result of participating in the offsite portion of the exercise, the scenario has been compromised.
To ensure exercise integrity, PPL is developing a new scenario, which will require NRC review and approval.
Several activities are necessary to modify the exercise. These activities include:
modifying the approved scenario to ensure exercise integrity is maintained, revalidating the modified scenario, formulating scenario logistics with drill controllers and evaluators, presenting the modified scenario to NRC Region I for approval prior to conducting the exercise. In addition, the SSES biennial exercise had been selected for participation by NRC Region I. PPL may need to brief the NRC Region I response team if the NRC decides to participate in the rescheduled exercise.
Currently, Unit 1 has returned to full power operation. Based on the results of the Unit 1 turbine blade outage, PPL determined that is was necessary to shutdown Unit 2. Because of the time needed to develop a new exercise scenario, the onsite portion of the biennial
Attachment to PLA-6937 Page 5 of 5 exercise requires rescheduling beyond the 2012 calendar year. Rescheduling the exercise to February 26, 2013 results in approximately 28 months between biennial exercises, which is still within the RIS guidance of 13 to 35 months. Since this exemption only provides temporary relief, the intent of the regulation is met.
The underlying intent of 10 CFR 50, Appendix E, Section IV.F.2.b is to ensure that the emergency response organization personnel are familiar with their duties and to test the adequacy of the emergency plans. The intent is met by performing emergency plan drills and exercises which are in excess of the regulatory requirement. This provides the opportunity to train personnel and improve emergency plans. The training drills conducted since the 2010 biennial exercise and identified in Tables 1 and 3 of the Attachment to Reference 2, have adequately demonstrated the effectiveness of the emergency plans and the ability of the emergency response personnel to execute them.
Lessons learned and programmatic enhancements from these drills have been included in the station's corrective action program.
Based on the previously discussed information in Reference 2 and the above discussion, a one-time exemption from the requirements of Section IV.F.2.b of Appendix E to 10 CFR 50 to reschedule the onsite biennial EP exercise until February 26, 2013 is requested by PPL. This exemption request is authorized by law, will not present an undue risk to the public health and safety, is consistent with the common defense and security, and special circumstances are present as set forth in 10 CFR 50.12(a)(2).