ML14183A013

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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 Constellation icon.png
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)
v • d • e


Text

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

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 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.

Docket No: 50-289

Enclosure:

Audit plan cc w/ encl: Distribution via Listserv Stephen Philpott, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation 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 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 Participants

  • Shift Emergency Director (ED)
  • Shift Comm
  • Security Shift Supervisor
  • Shift Maint
  • Shift Radiological Protection (RP) Tech RRC Proof of Concept Objectives TMI Simulated Control Room South Office Building (Unit 1 Admin Building)

Middletown, PA Objective Est Actual Expected Actions Time lEvent hour\ Demonstrate the ability of the

  • Shift Comm calls Nuclear licensee to perform the initial 8:00-8:30 Duty Officer (NDO) to notify request for SAFER FLEX (0-1) sec Phase 3 equipment 8:30-9:00
  • Shift ED advises CEO of priority of equipment, nature (1-2) of incident, selected SA Demonstrate effective location, & status of site communications and access routes coordination with the EOF 10:30-12:00
  • Shift ED advises CEO that (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 Assessing and clearing of (6-15) access route impediments 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 10:00-10:30 requirements for equipment RP (Protected Area (6-15) & personnel (Security/RP) requirements)
  • assesses additional resources to call in
  • transitions from Phase 1 (installed) to Phase 2 Demonstrate effective Throughout equipment (onsite portable)

Command and Control demonstration

  • make plans to transition 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 8:00-8:30 Supply

  • Corporate licensee to perform the initial o Corp Duty Supply calls Emergency request for SAFER FLEX (0-1) SAFER 24/7 contact point Director Phase 3 equipment
  • EOF 8:00-8:30 o Logistics Manager obtains (0-1) Corp Duty Supply contact Logistics info from NDO, gets Manager turnover from Corp Duty
  • EOF Admin Coordinator Supply, and assumes role of SPOC
  • EOF Security o SPOC advises SAFER of Coordinator 8:30-9:00 priority of equipment and
  • NDO* Demonstrate effective (1-2) nature of incident
  • Corporate coordination between the site o The SPOC communicates a Duty Supply
  • Single Point of Contact staging area "C" or "D" (SPOC) and the SAFER location and the associated

(*at normal Control Center(SCC) until the access routes that are both work location)

SAFER SA Lead is operational accessible and available for at the staging area. intended operations (status of site access routes) Throughout o SCC and SPOC have 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 coordination with SA "C" 1 SA 10:00-12:00
  • After instructed by CED, Lead (6-20) SPOC notifies SA Lead to 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 coordination with state and coordinates the escort of local agencies I officials the trucks with the State when they arrive at the PA border
  • coordinate clearing of route impediments from SA C to SAB
  • The SPOC and SA Lead Simulate the Utility's SPOC 12:00-13:00 communicate to the sec support for the turnover of (20-24) that RRC equipment has equipment.

been received and turned over to utility personnel.

Participants

  • PA Bureau of Rad Prot (BRP)
  • Lancaster County
  • Dauphin County RRC Proof of Concept Objectives Emergency Offsite Facility (EOF)-State and Local Agencies Exelon EOF for TMI Coatesville, PA Objective Est Actual Expected Actions Time {Event hour) Demonstrate effective licensee 8:30-9:00
  • assesses plant access and interface with the state (1-2) area infrastructure (routes and local representatives and to SA C/8 and site, etc.) the state and local officials' familiarity with licensee needs and requirements 9:00-10:00
  • coordinates clearing of (2-6) route impediments from SA "C" to SA "8" 10:00-10:30
  • When Fed Ex trucks nearing (6-15) PA border, PSP set up police escort to SA "C" 12:00-13:00
  • supports escort of convoy to (20-24) SA "B", if necessary Participants
  • Site RP Supervisor
  • Lancaster Airport Officials RRC Proof of Concept Objectives Staging Area "C" Lancaster Airport Lititz, PA Objective Est Actual Time lEvent hour) Demonstrate the ability to provide essential services for 8:30-10:00 staging area personnel.

(1-6) 9:00-10:00 (2-6) 10:30-12:00 Demonstrate effective (15-20) coordination between the licensee and SA "C" Demonstrate mobilization of staging area personnel.

10:00-10:30 (handled by SCC SA (6-15) Coordinator)

Demonstrate the ability to 10:00-10:30 establish and maintain staging (6-15) area facilities and equipment.

Demonstrate the ability to manage arriving transportation 10:00-10:30 providers upon arrival at the (6-15) staging area. Expected Actions

  • SA Coordinator will establish essential services (lodging, food, shelter), see also Appendix 5C, step 5.
  • SA C Facilities Mgr contacted by SPOC to ensure airport is ready
  • RP Supervisor dispatched by Augmented ERO (prestaged at SA "C")
  • RP Supervisor briefs personnel being dispatched to SA B -rad brief[KI, RWP, emergency worker)] -safety brief -escort arrangements

-plant/road conditions

  • SA personnel arrive at SA "C" at the required time (pre-staged) and establish communications with the sec
  • SA Lead simulates establishing an operational staging area lAW with Appendix 50 and 5E.
  • SA Lead monitor the arrival of trucks and equipment as documented on Appendix 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.)

Participants Augmented ERO:

  • Station Emergency Director
  • Site Security Coordinator
  • Site Ops Supervisor
  • Site RP Supv RRC Proof of Concept Objectives Augmented ERO and Staging Area "B" South Office Building (Unit 1 Admin Building)

I Adjacent Parking Lot Middletown, PA Objective Est Actual Expected Actions Time rEvent hour) Assessing and clearing of

  • prioritizes

& prepares to 10:30-12:00 receive equipment at SA "B" access routes, preps to (15-20)

  • Security coordinates access receive shipment, coordination and escort arrangements with Security I RP (Protected for personnel entering Area requirements)

Protected Area

  • equipment arrives at SA "B"
  • SAFER SA B personnel 12:00-13:00 direct rigging and Simulate delivery I receipt and (20-24) offloading of equipment turnover of equipment at (simulated), Staging Area (SA) "B"
  • SAFER SA B personnel conduct equipment turnover and initial operation with site p_ersonnel (simulated)

Participants

  • RRC Lead RRC Proof of Concept Objectives Regional Response Center Memphis, TN Objective Est Actual Time (Event hour) Demonstrate the activation of 8:00-8:30 the RCC functions within 60 (0-1) minutes from a utility request. Demonstrate command and 8:00-8:30 control of operations at the (0-1) RRC. Simulate the ability to execute 8:30-10:00 a loading and shipping (1-6) strategy.

Simulate deployment of equipment shipments from the 9:00-10:00 RRC. (2-6) Simulate deactivation of the 12:00-13:00 RRC. (20-24) Expected Actions

  • RRC staffing for activation occurs within 60 minutes from a utility request. Documented on SAFER Response Plan (SRP) Appendix 3C.
  • The facility is functional as documented on SRP Appendix 3A.
  • The RRC Lead initiates SRP Appendix 3D for initial contact.
  • The equipment is identified by review of the SRP Chapter 7 equipment list.
  • FedEx arrives at RRC (simulated)
  • Briefings are conducted lAW SRP Appendix 3E.
  • The RRC is deactivated lAW SRP Appendix 38, (as required).

Participants

  • sec L&T Coordinator
  • sec sA Coordinator RRC Proof of Concept Objectives SAFER Control Center Lynchburg, VA Objective Est Actual Time (Event hour) Demonstrate the ability of the 8:00-8:30 SAFER 24/7 notification point (0-1) to receive a request for FLEX Phase 3 equipment and to notify the SAFER SCC Lead within 15 minutes. Demonstrate the ability of SAFER to notify sec 8:00-8:30 personnel to report to the (0-1) demonstration sec. Demonstrate the ability of SAFER to notify RRC 8:00-8:30 personnel to report to the (0-1) demonstration RRC. Demonstrate the activation of 8:00-8:30 the sec within 60 minutes (0-1) from a utility request Demonstrate the activation of the Staging Area Coordinator 8:00-8:30 function at the sec within 60 (0-1) minutes from a utility request. Demonstrate the activation of the L& T function at the SCC 8:00-8:30 within 60 minutes from a utility (0-1) request. Demonstrate mobilization of 8:00-8:30 staging area personnel.

(0-1) Demonstrate command and 8:30-9:00 control of the SAFER (1-2) response via the SCC Lead. and Throughout Expected Actions

  • SAFER 24/7 contact receive a request, log the time and notify the SAFER Team within 15 minutes following receipt of a request for RRC equipment.
  • sec personnel receive notification and respond.
  • RRC personnel receive notification and respond.
  • sec minimum staffing for activation is achieved within 60 minutes from a utility request and is documented in Appendix 2C of the SAFER Response Plan (SRP).
  • The SA Coordinator arrives at the sec within the required time period as documented in SRP Appendix 2C .
  • The L&T Coordinator arrives at the sec within the required time period as documented in SRP Appendix 2C .
  • SA Coordinator identifies limited personnel and directs deployment to the staging area lAW SRP Appendix 5C.
  • The following are completed within 60 minutes of arrival: -SRP Appendix 2A (Facility Preparation) demonstration

-SRP Appendix 2D (Initial Contact Checklist)

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

access route accessibility.

-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 Demonstrate the ability to 8:30-9:00 the proposed travel routes assess travel route conditions (1-2) and modes with the between the RRC and Staging transportation provider.

Areas B, Cor D.

  • L& T Coordinator-Determines a Fly or Drive decision as documented in SRP Appendix 4C.
  • L& T Coordinator-Notifies the SCC of the ETA of Demonstrate the ability to Throughout transportation providers.

coordinate the departure of Demonstration

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

is a change.

  • 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.

Docket No.: 50-289

Enclosure:

Audit plan cc w/ encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL1 R/F RidsNrrDorllpl1-2 Resource RidsNrrPMThreeMilelsland Resource RidsNrrLASLent Resource RidsAcrsAcnw_MaiiCTR Resource ADAMS Accession No ML14183A013 OFFICE NRR/JLD/JOMB/PM NAME SPhilpott DATE 07/02/14 OFFICE NRR/ JLD/JOMB/BC NAME JBowen DATE 07/02/14 Sincerely, IRA/ Stephen Philpott, Project Manager Orders Management Branch Japan Lessons Learned Division Office of Nuclear Reactor Regulation RidsRgn1 Mail Center Resource SPhilpott, NRR/JLD JBowen, NRR/ JLD MHalter, NRR/JLD NRR/JLD/JOMB/PM NRR/JLD/LA MHalter Slent 07/02/14 07/02/14 NRR/JLD/JOMB/PM SPhilpott 07/02/14 OFFICIAL AGENCY RECORD

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