ML14183A013

Plan to Audit the Regional Response Center Proof of Concept Demonstration with Three Mile Island Nuclear Station, Unit 1 Regarding Implementation of Phase 3 Related to Order EA-12-049 (Mitigating Strategies)

ML14183A013
Person / Time
Site:	Three Mile Island
Issue date:	07/02/2014
From:	Stephen Philpott Japan Lessons-Learned Division
To:	Pacilio M Exelon Nuclear
Philpott S, NRR/JLD, 415-2365
References
EA-12-049
Download: ML14183A013 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 2, 2014 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

PLAN TO AUDIT THE REGIONAL RESPONSE CENTER PROOF OF CONCEPT DEMONSTRATION WITH THREE MILE ISLAND NUCLEAR STATION, UNIT 1 REGARDING IMPLEMENTATION OF PHASE 3 RELATED TO ORDER EA-12-049 (MITIGATING STRATEGIES)

Dear Mr. Pacilio:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A736), requiring holders of operating licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of the order will be achieved.

This order requires a three-phase approach for mitigating beyond-design-basis external events.

The initial phase requires the use of installed equipment and resources to maintain or restore core cooling, containment and spent fuel pool (SFP) cooling capabilities. The transition phase requires providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The final phase requires obtaining sufficient offsite resources to sustain those functions indefinitely.

Industry is working cooperatively via the Strategic Alliance for FLEX Emergency Response (SAFER) to implement Regional Response Centers (RRCs) in Memphis, TN, and Phoenix, AZ as the repositories for offsite resources.

On July 10, 2014, the SAFER organization and staff from Three Mile Island Nuclear Station, Unit 1 (TMI) plan to conduct a demonstration of SAFER's ability to activate the SAFER Control Center ,as well as the Memphis RRC and deliver Phase 3 off-site equipment to the TMI site in accordance with the SAFER response plan. The enclosed document outlines the audit process that the NRC staff will follow while observing this demonstration. The NRC staff will document its observations from the demonstration as part of its evaluation of the readiness of the RRCs and the SAFER organization to support Phase 3 of licensees' Mitigating Strategies in response to Order EA-12-049.

M. Pacilio If you have any questions, please contact me at 301-415-2365 or by e-mail at Stephen. Philpott@nrc.gov.

Stephen Philpott, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No: 50-289

Enclosure:

Audit plan cc w/ encl: Distribution via Listserv

Audit Plan SAFER Response Proof of Concept Demonstration Three Mile Island Nuclear Station, Unit 1 Regional Response Center- Memphis, TN SAFER Control Center- Lynchburg, VA BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A736), requiring holders of operating licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of the order will be achieved. In accordance with the order, the OIPs were submitted by February 2013, and required subsequent 6-month updates were submitted in August 2013 and February 2014. Licensees are in the process of implementing the requirements identified in the order. Licensees are required to complete full implementation no later than two refueling cycles after submittal of the OIPs or by December 31, 2016, whichever comes first.

Since receiving the OIPs, the NRC staff has started the audit process, as well as reviewing any related additional information, to determine the extent to which the licensees are proceeding on a path towards successful implementation. The NRC staff has provided feedback to licensees on their submittals via Interim Staff Evaluations (ISEs); which were completed in February 2014.

Order EA-12-049 requires a three-phase approach for mitigating beyond-design-basis external events (BDBEE). The initial phase requires the use of installed equipment and resources to maintain or restore core cooling, containment and spent fuel pool (SFP) cooling capabilities.

The transition phase requires providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The final phase requires obtaining sufficient offsite resources to sustain those functions indefinitely. Industry is working cooperatively to implement Regional Response Centers (RRCs) in Memphis, TN and Phoenix, AZ as the repositories for offsite resources. The cooperative organization formed to manage and maintain these offsite resources and implement the Phase 3 offsite response is the Strategic Alliance for FLEX Emergency Response (SAFER).

The SAFER organization and staff from Three Mile Island Nuclear Station, Unit 1 (TMI) plan to conduct a demonstration of SAFER's ability to activate the SAFER Control Center (SCC) in Lynchburg, VA, as well asa the Memphis RRC, and deliver Phase 3 offsite equipment to the TMI site in accordance with the SAFER response plan on July 10, 2014. This document outlines the audit process that the NRC staff will follow while observing this demonstration. The NRC staff will document its observations from the proof-of-concept demonstration as part of its evaluation of the readiness of the RRCs and the SAFER organization to support Phase 3 of licensees' Mitigating Strategies in response to Order EA-12-049.

Enclosure

NRC staff will observe and evaluate the Proof-of-Concept demonstration in accordance with the SAFER Response Plan based on the requirements in Order EA-12-049.

The Nuclear Energy Institute (NEI) developed NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" in August, 2012 (ADAMS Accession No.

ML12242A378) to outline a process, by which, individual licensees would define and implement site-specific diverse and flexible mitigation strategies that reduce the risk associated with beyond-design-basis conditions. FLEX represents the industry's approach to addressing the three phase approach for mitigation strategies, as described above. This guide was endorsed, with clarifications, by NRC interim staff guidance (ISG) JLD-ISG-2012-01 "Compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML12229A174).

AUDIT SCOPE The purpose of the audits is to observe the industry's RRC proof-of-concept demonstration in order to evaluate: (1) coordination between the licensee, the SAFER organization, and state and local officials in a simulated BDBEE scenario requiring the need for offsite equipment, and (2) the SAFER organization's ability and readiness to deliver needed offsite equipment to a United States nuclear power plant to support the licensees' Phase 3 strategies needed to comply with Order EA-12-049 ( Mitigating Strategies ).

The audit will be performed in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits," (ADAMS Accession No. ML082900195) to support the development of safety evaluations regarding licensees' final integrated plans in response to Order EA-12-049.

NRC AUDIT TEAM AND LOGISTICS NRC staff will observe the RRC Proof-of-Concept demonstration at various locations at or near TMI, at the SAFER Control Center in Lynchburg, VA, and at the RRC in Memphis, TN on July 10, 2014.

Area of Review Assigned Auditor(s)

TMI Simulated Control Room John Hughey, NRR Eric Schrader, NSIR EOF ERO I Exelon Corporate Mandy Halter, NRR Amanda Marshall, NSIR EOF - State & Local Agencies Stephen Monarque, NRR Amanda Marshall, NSIR Staging Area "C" Joshua Miller, NRR Staging Area "B" John Hughey, NRR Eric Schrader, NSIR TMI Area - Additional Observers Jack Davis, NRR Jeremy Bowen, NRR Ho Nieh, Rl

Mohammed Shuaibi, Rill

'

RRC - Memphis, TN Stephen Philpott, NRR Jason Paige, NRR Sheena Whaley, NRR SAFER Control Center- Lynchburg, VA Eric Bowman, NRR Joseph Anderson, NSIR DELIVERABLES NRC staff will conduct an exit meeting via conference call with the SAFER organization and TMI staff on a date to be determined following the RRC Proof-of-Concept demonstration in order to provide verbal observations.

Formal NRC observations will be documented in a report format following the SAFER organization's notification to the NRC that the RRCs are operational. NRC staff currently estimates that this report will be issued to the SAFER organization in September 2014.

INFORMATION NEEDS

• Latest version of the TMI SAFER Response Plan ("playbook")

• RRC - SAFER Plan for Proof of Concept

• TMI operator and staff procedures

NRC Staff Schedule (Subject to change based on timing of the demonstration)

Thursday, July 10, 2014 0730 Check in at demonstration locations 0800 Begin exercise 1300 Conclude Exercise 1300 Lunch 1430 Controllers exercise review with participants (conference call with all locations) 1530 Departure

RRC Proof of Concept Objectives TMI Simulated Control Room South Office Building (Unit 1 Admin Building)

Middletown, PA Participants Objective Est Actual Expected Actions Time lEvent hour\

Demonstrate the ability of the

• Shift Comm calls Nuclear

• Shift licensee to perform the initial 8:00-8:30 Duty Officer (NDO) to notify Emergency request for SAFER FLEX (0-1) sec Director (ED) Phase 3 equipment

• Shift Comm

• Security Shift

• Shift ED advises CEO of 8:30-9:00 priority of equipment, nature Supervisor (1-2) of incident, selected SA

• Shift Maint

• Shift Demonstrate effective location, & status of site Radiological communications and access routes Protection coordination with the EOF 10:30-12:00

• Shift ED advises CEO that (RP) Tech (15-20) SA "B" is ready to receive equipment.

8:30-9:00

• Assesses plant access &

(1-2) area infrastructure (SA "B",

routes, etc.)

10:00-10:30

• coordinates clearing of access route impediments Assessing and clearing of (6-15) to SA "B" access routes, preps to

• makes preparations to receive shipment receive shipments at SA "B" (equipment movement, operation, connection, refueling, etc.)

• determines Protected Area Coordination with Security I requirements for equipment 10:00-10:30 RP (Protected Area & personnel (Security/RP) requirements) (6-15)

• assesses additional resources to call in

• transitions from Phase 1 (installed) to Phase 2 Demonstrate effective equipment (onsite portable)

Throughout Command and Control

• make plans to transition demonstration Structure for a BDBEE from Phase 2 to Phase 3 equipment

• as Augmented ERO arrives, establishes reporting location

RRC Proof of Concept Objectives Emergency Offsite Facility (EOF) Emergency Response Organization(ERO) I Exelon Corporate Exelon EOF for TMI Coatesville, PA Participants Objective Est Actual Expected Actions Time (Event hour}

Demonstrate the ability of the o NDO Calls Corp Duty

• Corporate licensee to perform the initial 8:00-8:30 Supply Emergency o Corp Duty Supply calls request for SAFER FLEX (0-1)

Director Phase 3 equipment SAFER 24/7 contact point

• EOF Director

• EOF 8:00-8:30 o Logistics Manager obtains Logistics (0-1) Corp Duty Supply contact Manager info from NDO, gets

• EOF Admin turnover from Corp Duty Coordinator Supply, and assumes role

• EOF Security of SPOC Coordinator o SPOC advises SAFER of 8:30-9:00 priority of equipment and

• NDO* Demonstrate effective (1-2)

• Corporate nature of incident coordination between the site Duty Supply

• o The SPOC communicates a Single Point of Contact staging area "C" or "D" (SPOC) and the SAFER

(*at normal location and the associated Control Center(SCC) until the work location) access routes that are both SAFER SA Lead is operational accessible and available for at the staging area.

intended operations (status of site access routes) o SCC and SPOC have Throughout periodic updates on demonstration shipment & routes (location/ETA) & mitigates potential issues/delays o The SPOC coordinates Throughout access of SAFER demonstration equipment and personnel to the nuclear site (i.e.,

Demonstrate the ability to identifies access route to support the access of SAFER SA B and facilitates personnel and equipment to provisions for entry into the nuclear site (i.e., assess restricted access areas).

and select access route and o Assesses plant access and staging area, entry to site 8:30-9:00 area infrastructure (SA B, protected areas). (1-2) routes, road conditions w/in 25-mile radius, etc.)

9:00-10:00 o coordinates clearing of (2-6) access routes with EOC

• SPOC interfaces with SA Lead Demonstrate effective

• After instructed by CED, 10:00-12:00 coordination with SA "C" 1 SA SPOC notifies SA Lead to Lead (6-20) release equipment to site &

coordinates truck escort with EOC, if requested

• State I Local agencies assess plant access and Throughout area infrastructure (routes demonstration to SAC and the site/SA B)

Demonstrate effective

• Logistics Manager coordinates the escort of coordination with state and the trucks with the State local agencies I officials when they arrive at the PA border

• coordinate clearing of route impediments from SA C to SAB

• The SPOC and SA Lead 12:00-13:00 communicate to the sec Simulate the Utility's SPOC (20-24) that RRC equipment has support for the turnover of been received and turned equipment.

over to utility personnel.

RRC Proof of Concept Objectives Emergency Offsite Facility (EOF)- State and Local Agencies Exelon EOF for TMI Coatesville, PA Participants Objective Est Actual Expected Actions Time

{Event hour)

Demonstrate effective licensee 8:30-9:00

• assesses plant access and

• PEMA interface with the state (1-2) area infrastructure (routes

• PA Bureau of and local representatives and to SA C/8 and site, etc.)

Rad Prot the state and local officials' (BRP) familiarity with licensee needs

• PA State and requirements 9:00-10:00

• coordinates clearing of Police (PSP) (2-6) route impediments from SA

• Lancaster "C" to SA "8" County

• Dauphin

• When Fed Ex trucks nearing County 10:00-10:30 (6-15) PA border, PSP set up police escort to SA "C" 12:00-13:00

• supports escort of convoy to SA "B", if necessary (20-24)

RRC Proof of Concept Objectives Staging Area "C" Lancaster Airport Lititz, PA Participants Objective Est Actual Expected Actions Time lEvent hour)

Demonstrate the ability to

• SA Coordinator will

• Site RP provide essential services for 8:30-10:00 establish essential services Supervisor staging area personnel. (1-6) (lodging, food, shelter), see

• SAFER SA also Appendix 5C, step 5.

Lead 9:00-10:00

• SA C Facilities Mgr

• SAFER SA (2-6) contacted by SPOC to Technician ensure airport is ready

• Lancaster

• RP Supervisor dispatched Airport by Augmented ERO 10:30-12:00 Officials (prestaged at SA "C")

Demonstrate effective (15-20)

• RP Supervisor briefs coordination between the personnel being dispatched licensee and SA "C" to SA B

- rad brief[KI, RWP, emergency worker)]

- safety brief

- escort arrangements

- plant/road conditions Demonstrate mobilization of

• SA personnel arrive at SA staging area personnel. 10:00-10:30 "C" at the required time (handled by SCC SA (6-15) (pre-staged) and establish Coordinator) communications with the sec

• SA Lead simulates establishing an operational Demonstrate the ability to 10:00-10:30 staging area lAW with establish and maintain staging (6-15) Appendix 50 and 5E.

area facilities and equipment.

• SA Lead reports to SCC Team Lead that SAC is operational Demonstrate the ability to

• SA Lead monitor the arrival manage arriving transportation 10:00-10:30 of trucks and equipment as providers upon arrival at the (6-15) documented on Appendix staging area. 51.

Demonstrate command and SA lead will:

control of the offsite staging 10:00-10:30

• Assume the role of area (SA "C") and the ability to (6-15) communicator with the manage the movement and SPOC from the SCC Lead.

release of shipments from the

• Conduct staging area offsite staging area to the on- briefings as documented on site staging area (SA "B"). Appendix 5H.

10:30-12:00

• Release equipment (15-20) shipments as directed by the SPOC (When directed by the SPOC, SA Lead instructs truck drivers to deploy to site with specified equipment.)

RRC Proof of Concept Objectives Augmented ERO and Staging Area "B" South Office Building (Unit 1 Admin Building) I Adjacent Parking Lot Middletown, PA Participants Objective Est Actual Expected Actions Time rEvent hour)

• prioritizes & prepares to Assessing and clearing of Augmented ERO: 10:30-12:00 receive equipment at SA "B" access routes, preps to

• Station receive shipment, coordination (15-20)

• Security coordinates access Emergency and escort arrangements with Security I RP (Protected Director for personnel entering Area requirements)

• Site Security Protected Area Coordinator

• equipment arrives at SA "B"

• Site Ops

• SAFER SA B personnel Supervisor 12:00-13:00 direct rigging and

• OSC Director Simulate delivery I receipt and (20-24) offloading of equipment

• Site RP Supv turnover of equipment at (simulated),

Staging Area (SA) "B"

• SAFER SA B personnel conduct equipment turnover and initial operation with site p_ersonnel (simulated)

RRC Proof of Concept Objectives Regional Response Center Memphis, TN Participants Objective Est Actual Expected Actions Time (Event hour)

• RRC staffing for activation

• RRC Lead Demonstrate the activation of 8:00-8:30 occurs within 60 minutes the RCC functions within 60 (0-1) from a utility request.

minutes from a utility request. Documented on SAFER Response Plan (SRP)

Appendix 3C.

• The facility is functional as Demonstrate command and 8:00-8:30 documented on SRP control of operations at the (0-1) Appendix 3A.

RRC.

• The RRC Lead initiates SRP Appendix 3D for initial contact.

• The equipment is identified by review of the SRP Simulate the ability to execute 8:30-10:00 Chapter 7 equipment list.

a loading and shipping (1-6)

• FedEx arrives at RRC strategy. (simulated)

• Briefings are conducted lAW SRP Appendix 3E.

• Inform the SAFER SCC Simulate deployment of 9:00-10:00 Team Lead when all the equipment shipments from the (2-6) equipment has left the RRC.

RRC.

• The RRC is deactivated Simulate deactivation of the 12:00-13:00 lAW SRP Appendix 38, (as RRC. required).

(20-24)

RRC Proof of Concept Objectives SAFER Control Center Lynchburg, VA Participants Objective Est Actual Expected Actions Time (Event hour)

• SAFER 24/7 contact Demonstrate the ability of the

• sec Lead SAFER 24/7 notification point 8:00-8:30 receive a request, log the

• sec L&T to receive a request for FLEX (0-1) time and notify the SAFER Coordinator Team within 15 minutes Phase 3 equipment and to

• sec sA notify the SAFER SCC Lead following receipt of a Coordinator request for RRC within 15 minutes.

equipment.

Demonstrate the ability of

• sec personnel receive SAFER to notify sec 8:00-8:30 notification and respond.

personnel to report to the (0-1) demonstration sec.

Demonstrate the ability of

• RRC personnel receive SAFER to notify RRC 8:00-8:30 notification and respond.

personnel to report to the (0-1) demonstration RRC.

• sec minimum staffing for 8:00-8:30 activation is achieved within Demonstrate the activation of (0-1) 60 minutes from a utility the sec within 60 minutes request and is documented from a utility request in Appendix 2C of the SAFER Response Plan (SRP).

Demonstrate the activation of

• The SA Coordinator arrives the Staging Area Coordinator 8:00-8:30 at the sec within the function at the sec within 60 (0-1) required time period as minutes from a utility request. documented in SRP Appendix 2C .

Demonstrate the activation of

• The L&T Coordinator the L& T function at the SCC 8:00-8:30 arrives at the sec within within 60 minutes from a utility (0-1) the required time period as request. documented in SRP Appendix 2C .

• SA Coordinator identifies Demonstrate mobilization of 8:00-8:30 limited personnel and staging area personnel. (0-1) directs deployment to the staging area lAW SRP Appendix 5C.

8:30-9:00

• The following are Demonstrate command and (1-2) completed within 60 control of the SAFER and minutes of arrival:

response via the SCC Lead.

Throughout - SRP Appendix 2A (Facility Preparation)

demonstration - SRP Appendix 2D (Initial Contact Checklist)

• Periodic communications 8:30-10:30 with the SPOC occur Demonstrate effective regarding the assessment communications via the sec (1-15) and selection of staging Lead and the site's Single area and the associated Point of Contact (SPOC) until access route accessibility.

the staging area is operational.

- Periodic briefings are conducted lAW SRP Appendix 2E.

• L& T Coordinator- Notifies Demonstrate the ability to 8:30-9:00 ground transport providers notify and provide reporting (1-2) using SRP Addendum B instructions to ground contact information (directs transport providers for RRC Fed Ex to report to RRC, shipments. determines mode of transportation, and notifies RRC)

• L& T Coordinator- Reviews 8:30-9:00 the proposed travel routes Demonstrate the ability to (1-2) and modes with the assess travel route conditions transportation provider.

between the RRC and Staging

• L& T Coordinator-Areas B, Cor D.

Determines a Fly or Drive decision as documented in SRP Appendix 4C.

• L& T Coordinator- Notifies the SCC of the ETA of Throughout transportation providers.

Demonstrate the ability to Demonstration

• L& T Coordinator- Acquires coordinate the departure of a status from transportation shipments from the RRC and providers hourly or if there to maintain a status on the is a change.

shipments.

• L& T Coordinator-Coordinate action for abnormal conditions lAW SRP Aopendix 4B Simulate command and

• The SCC Team Lead control for deactivation of the 12:00-13:00 deactivates the sec as sec. (20-24) documented in SRP Appendix 2B, (as required).

M. Pacilio If you have any questions, please contact me at 301-415-2365 or by e-mail at Stephen. Philpott@nrc.gov.

Sincerely, IRA/

Stephen Philpott, Project Manager Orders Management Branch Japan Lessons Learned Division Office of Nuclear Reactor Regulation Docket No.: 50-289

Enclosure:

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