PLA-6922, Exemption Request from the Biennial Emergency Preparedness Exercise Requirements of 10 CFR 50, Appendix E, Section IV.F.2.b
| ML12300A108 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/25/2012 |
| From: | Rausch T Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-6922 | |
| Download: ML12300A108 (18) | |
Text
Timothy S. Rausch Sr. Vice President-ChiefNuclear Officer OCT 2 5 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3445 Fax 570.542.1504 tsrausch@pplweb.com SUSQUEHANNA STEAM ELECTRIC STATION EXEMPTION REQUEST FROM THE BIENNIAL EMERGENCY PREPAREDNESS EXERCISE REQUIREMENTS OF 10 CFR 50, APPENDIX E, SECTION IV.F.2.b PLA-6922 Docket Nos. 50-387 and 50-388
Reference:
NRC Regulatory Issue Summary 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements, "
dated February 24, 2006.
Pursuant to 10 CFR 50.12, "Specific Exemptions," PPL Susquehanna, LLC (PPL) requests the U.S. Nuclear Regulatory Commission (NRC) approval of an exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.b. Specifically, PPL requests postponement of the evaluation of the onsite elements of the Susquehanna Steam Electric Station's (SSES 's) biennial Emergency Preparedness exercise. This exemption request results from special circumstances that were unavoidable due to a necessary unplanned Unit 1 outage. The outage is necessary to address fatigue cracking experienced on the Unit 1 turbine blades.
. The Attachment to this letter provides the basis and justification for this exemption request and addresses the exemption requirements of 10 CFR 50.12 and the guidance criteria contained in NRC Regulatory Issue Summary 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements." Note that the offsite portion of the biennial exercise was successfully performed on October 23, 2012.
Document Control Desk PLA-6922 If you have any questions regarding this exemption request, please contact Mr. John L. Tripoli, Manager, Nuclear Regulatory Affairs, at (570) 542-3100.
This letter contains no new regulatory commitments.
T. S. Rausch Senior Vice President-Chief Nuclear Officer Copy: Mr. S. T. Barr, NRC Region I Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. J. Whited, NRC Project Manager Mr. L. Winker, P A DEP/BRP Administrator, NRC Region I
Attachment to PLA-6922 Exemption Request from the Onsite Portion of the Biennial Emergency Preparedness Exercise Requirements -10 CFR 50, Appendix E,Section IV.F.2.b
Purpose Attachment to PLA-6922 Page 1 of19 Exemption Request from the Onsite Portion of the Biennial Emergency Preparedness Exercise Requirements -
10 CFR 50, Appendix E, Section IV.F.2.b The following information provides PPL Susquehanna, LLC's (PPL) basis for an exemption from the requirements of 10 CPR 50, Appendix E,Section IV.F.2.b.
Specifically, PPL is requesting to reschedule the onsite portion of the Susquehanna Steam Electric Station (SSES) biennial Emergency Preparedness (EP) exercise from October 23, 2012, to February 26, 2013. The offsite portions of the SSES biennial EP exercise were performed on October 23, 2012. This exemption request results from special circumstances that were unavoidable due to a necessary unplanned Unit 1 outage.
The outage is necessary to address fatigue cracking experienced on the Unit 1 turbine blades. This request for exemption is consistent with the guidance specified in Nuclear Regulatory Commission (NRC) Regulatory Issue Summary (RIS) 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements," dated February 24, 2006.
Special Circumstances The PPL full participation and FEMA evaluated biennial exercise was scheduled to be conducted on October 23,2012. On October 3, 2012, PPL received a recommendation from its low pressure (LP) turbine (non-safety related equipment) supplier to remove the Unit 1 Main Turbine from service to perform LP turbine end blade root inspections. PPL reduced power to reduce blade tip vibration on both Unit 1 and Unit 2. Unit 1 was removed from service on October 20, 2012. Pending the outcome of the Unit 1 turbine inspection, PPL will determine whether a similar inspection of the Unit 2 turbine is warranted.
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 in operation.
NRC RIS 2006-03 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. The RIS provides a 13 to 35 month window to schedule exercises while still meeting the biennial requirement. A one-time change in the exercise schedule Document Control Desk PLA-6922 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 RIS. Since 1997, PPL has performed its biennial EP exercise in the falL The exercises were all scheduled in October except one exercise was in September and one was in November. This selected time frame is coordinated during scheduling conferences that take into consideration the scheduling of other EP exercises in Region I. PPL also has annual refueling outages that are scheduled in the spring. PPL's request to reschedule the onsite portion of the exercise results in 28 months between biennial exercises, which is still within the RIS guidance of 13 to 35 months.
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 performed, a challenging scenario was developed, and required submission dates for exercise scenarios were met. 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. 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. The offsite portion of the biennial exercise was successfully performed on October 23, 2012.
PPL believes the requested approach represents safe and conservative actions to perform these unexpected turbine inspection outages.
Justification for the Exemption In accordance with 10 CFR 50.12(a)(1), the NRC may grant exemptions from certain requirements of the 10 CFR 50 regulations that are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.
- 1. This exemption request is authorized by law:
The proposed exemption will allow PPL to reschedule the onsite portion of the biennial EP exercise from October 23, 2012, to February 26, 2013. This is necessary due to an unplanned Unit 1 outage to address the fatigue cracking experienced on the Unit 1 turbine blades, and a potential shutdown of Unit 2.
Inaccordance with 10 CFR 50.12, the NRC may grant an exemption from the requirements of 10 CFR 50 if the exemption is authorized by law. The proposed exemption is authorized by law in that no other prohibition of law exists to preclude the activities which would be authorized by the exemption. The proposed exemption will continue to serve the underlying purpose of the regulation. The purposes of the Document Control Desk PLA-6922 biennial EP exercise are to test the adequacy of the emergency plans, to ensure the emergency response organization personnel are familiar with their duties, and to identify and correct weaknesses. The activities performed during SSES's periodic drills, ongoing training, and response to plant or external events demonstrate that these underlying purposes of conducting an exercise have been met.
- 2. This exemption request will not present an undue risk to public health and safety:
Adequate emergency response capabilities have been maintained and demonstrated since the last SSES full participation biennial exercise (date October 5, 2010), through the conduct of drills, ongoing training, and response to plant or external events.
Exercises and Drills The previous full participation biennial exercise of the SSES emergency plan was performed on October 5, 2010. The results of this exercise concluded that the overall performance of the emergency response organization demonstrated that onsite emergency plans are adequate and that the organization is capable of implementing these plans. The NRC evaluated the 2010 biennial emergency plan exercise and provided the evaluation results in NRC Inspection Report 05000387/2010502 and 0500388/2010502, dated November 16,2010 (ML103200304). No NRC findings were identified.
Table 1 provides a list of the seven full-scale drills performed since the 2010 SSES full participation biennial EP exercise. These drills included activation of all of the licensee's emergency response facilities, and participation by the State of Pennsylvania and local agencies. The full-scale drills exercise the functions of SSES' s emergency response organization to respond to an emergency scenario involving radiological release and coordination of actions to mitigate the event. This includes the control room/simulator, Technical Support Center (TSC), Operations Support Center (OSC),
Emergency Operating Facility (EOF), and the Joint Information Center (JIC).
Coordination of actions and communications are practiced between these facilities and the State of Pennsylvania and risk county emergency management agencies to promote a high level of performance.
NRC RIS 2006-03 states the licensee shall take actions necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including at least one drill involving a combination of some of the principal functional areas of the licensee's onsite emergency response capabilities. The number of drills listed in Table 1 exceeds the one drill recommendation in NRC RIS 2006-03 and demonstrates PPL's continuing level of Document Control Desk PLA-6922 engagement in EP activities by SSES, the State of Pennsylvania and risk county agencies.
Table 1-Completed Full Scale Drills 2010-2012 Date 11116/2010 6/28/2011 8/23/2011 9/13/2011 11/0112011 2/07/2012 8/28/2012 PPL also conducted evaluated Licensed Operator Scenarios and individual facility Table Top drills (see Table 2 below) to ensure that key personnel maintain an understanding and focus on Emergency Plan initiating conditions. These drills also involved Performance Indicator (PI) activities.
Table 2 -Evaluated Licensed Operator Scenarios and Individual Facility Table Top Drills 2010-2012 Date Type of Drill 5/23/2011 Licensed Operator Scenarios 5/27/2011 Control Room Simulator Table Top 5/30/2011 Licensed Operator Scenarios 5/31/2011 Licensed Operator Scenarios 6/20/2011 Licensed Operator Scenarios 6/24/2011 Control Room Simulator Table Top 6/27/2011 Licensed Operator Scenarios 2117/2012 Control Room Simulator Table Top 3/02/2012 Control Room Simulator Table Top 3/09/2012 Control Room Simulator Table Top 3/19/2012 Control Room Simulator Table Top 3/20/2012 Technical Support Center (TSC) Table Top 5/18/2012 Emergency Operations Facility (EOF) Table Top 6/18/2012 Licensed Operator Scenarios 6/25/2012 Licensed Operator Scenarios 7/3/2012 Control Room Simulator Table Top_
7/9/2012 Licensed 02_erator Scenarios 7/16/2012 Licensed Operator Scenarios 7117/2012 Licensed Operator Scenarios
7/23/2012 7/27/2012 8/3/2012 8/17/2012 8/24/2012 Document Control Desk PLA-6922 Licensed Operator Scenarios Control Room Simulator Table Top_
Control Room Simulator Table Top Control Room Simulator Table Top Control Room Simulator Table Top PPL also conducted practice drills (see Table 3 below) to maintain proficiency of SSES's Emergency Response Organization. The TSC, EOF, OSC, and llC participated. SSES's practice drills exercise similar activities, except simulated data is provided in lieu of use of the simulator.
Table 3 -Practice Drills 2010-2012 Date 1112/2010 1/11/2011 6116/2011 8/09/2011 8/30/2011 10/18/2011 1117/2012 7113/2012 7/20/2012 7/27/2012 8/03/2012 8/14/2012 10/9/2012 Actual Events On August 23, 2011, an actual emergency event was declared due to an earthquake.
PPL declared an unusual event and the TSC was staffed for approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. In addition, during Tropical Storm Lee (September 2011), there was wide spread flooding in SSES EPZ risk counties adjacent to the plant and SSES emergency planning personnel assisted with the county response but no emergency plan entry was required for SSES.
Planned Drills for the Remainder of 2012 A Health Physics EP drill is tentatively scheduled for November 13, 2012. The date of this drill may change based on completion of the Unit 1 turbine outage and possible inspection of the Unit 2 turbine blades.
Training Document Control Desk PLA-6922 In addition to the above drills and exercises performed since the SSES 2010 biennial exercise, the following training has been completed with the onsite functions of the SSES Emergency Response Organization (see Table 4 below)
Table 4-EP Training Completed with SSES Onsite Functions 2010-2012 Course Number Course Name Date EP009 Dose Calculator Training 712612012 EP009R Dose Calculator Training 911512011 EP009R Dose Calculator Training 912112011 EP009R Dose Calculator Training 912212011 EP009R Dose Calculator Training 1211512011 EP009R Dose Calculator Training 712512012 EP009R Dose Calculator Training 81112012 EP009R Dose Calculator Training 81912012 EP009R Dose Calculator Training 8/1512012 EP009R Dose Calculator Training 812212012 EP009R Dose Calculator Training 812912012 EP009R Dose Calculator Training 9/11/2012 Dose Assessment & Protective Actions Training I EP010 Retraining 11412011 Dose Assessment & Protective Actions Training I EP010 Retraining 711412011 Dose Assessment & Protective Actions Training I EP010 Retraining 812712011 Dose Assessment & Protective Actions Training I EP010 Retraining 101612011 Dose Assessment & Protective Actions Training I EP010 Retraining 311512012 Dose Assessment & Protective Actions Training I EP010 Retraining 312112012 Dose Assessment & Protective Actions Training I EP010 Retraining 812912012 Dose Assessment & Protective Actions Training I EP010 Retraining 912512012 Dose Assessment & Protective Actions Training I EP010 Retraining 912812012 EP012 Emergency Classification Training I Retraining 11412011 EP012 Emergency Classification Training I Retraining 711412011 EP012 Emergency Classification Training I Retraining 812712011 EP012 Emergency Classification Training I Retraining EP012 Emergency Classification Training I Retraining EP013 Onsite Radiation Monitoring Team EP013 Onsite Radiation Monitoring Team EP013 Onsite Radiation Monitoring Team EP013 Onsite Radiation Monitoring Team EP013R Onsite Radiation Monitoring Team EP013R Onsite Radiation Monitoring Team EP013R Onsite Radiation Monitoring Team EP013R Onsite Radiation Monitoring Team EP013R Onsite Radiation Monitoring Team EP013R Onsite Radiation Monitoring Team EP013R Onsite Radiation Monitoring Team EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP017 Introduction to Radiation EP018 Plant Operator I Tour EP018 Plant Operator I Tour EP018 Plant Operator I Tour EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance EP021 Contaminated Injury - Ambulance Document Control Desk PLA-6922 10/712011 312212012 912112011 711712012 81112012 81912012 812512011 911512011 912912011 712512012 81112012 812912012 9/1112012 1012112010 1113012010 121912010 1211012010 2/1112011 211512011 211812011 212312011 31412011 112012012 113112012 21812012 513012012 612212012 1012212010 513012012 612212012 112412011 101512011 1011812011 1012212011 111312011 111412011 1111112011 1211312011 11612012 111612012 212912012 313012012
EP021 EP022 EP022 EP022 EP022R EP022R EP022R EP022R EP022R EP024 EP025 EP025R EP025R EP025R-11 EP025R-11 EP025R-11 EP025R-11 EP025R-11 EP053 EP053 EP053 EP053 EP054-11 EP054-11 EP054-11 EP054-11 EP054-11 EP054I EP054I EP054R EP054R EP054R EP054R EP054R EP054R EP054R EP054R EP054R EP054R EP054R EP054R EP054R Document Control Desk PLA-6922 Contaminated Injury - Ambulance 5/2/2012 Contaminated Injury -Hospital Training /Retraining 9/22/2011 Contaminated Injury -Hospital Training /Retraining 7/24/2012 Contaminated Injury -Hospital Training /Retraining 8/8/2012 Contaminated Injury -Hospital Training /Retraining 8/17/2011 Contaminated Injury -Hospital Trainin_g_ /Retraining 8/24/2011 Contaminated Injury -Hospital Training /Retraining 7/31/2012 Contaminated Injury -Hospital Training/Retraining 8116/2012 Contaminated Injury -Hospital Training /Retraining 8/30/2012 Post Accident Coolant Samgle 8/24/2011 Post Accident Vent Monitoring Sample 8/26/2011 Post Accident Vent Monitoring San~ple 2/3/2011 Post Accident Vent Monitoring Sa~ple 3/15/2011 Post Accident Vent Monitoring Sam_gle 2/3/2011 Post Accident Vent Monitoring Saii!Qle 2/9/2011 Post Accident Vent Monitoring Sample 2/16/2011 Post Accident Vent Monitoring Sample 2/23/2011 Post Accident Vent Monitoring Sample 3/15/2011 Offsite Team Management 2/15/2011 Offsite Team Management 6/21/2011 Offsite Team Management 2/23/2012 Offsite Team Management 3/7/2012 In-Plant Team Management Training I Retraining 2/4/2011 In-Plant Team Mana._gement Traini!!_g I Retrainin_g 2/10/2011 In-Plant Team Management Training I Retraining 2/17/2011 In-Plant Team Management Training I Retraining 2/24/2011 In-Plant Team Management Training I Retraining 3/18/2011 In-Plant Team Management Training I Retraining 11118/2010 In-Plant Team Management Training I Retraining 3/16/2012 In-Plant Team Management Training I Retraining 1/13/2011 In-Plant Team Management Training I Retraining 2/112011 In-Plant Team Management Training I Retraining 2/4/2011 In-Plant Team Management Training I Retraining 3/18/2011 In-Plant Team Management Training I Retraining 5/18/2011 In-Plant Team Management Training I Retraining 5/31/2011 In-Plant Team Management Training I Retraining 6/6/2011 In-Plant Team Management Training I Retraining 7/8/2011 In-Plant Team Management Training I Retraining 7/11/2011 In-Plant Team Management Training I Retraining 8/17/2011 In-Plant Team Management Training I Retrainin_g_
12/20/2011 In-Plant Team Management Training I Retraining 12/28/2011 In-Plant Team Management Training I Retraining 7/3112012
EP054R EP062 EP062 EP062E EP062E EP062E EP062E EP062R EP077 EP077 EP077 EP078 EP078 EP078 EP078 EP078 EP078 EP078 EP078E EP078E EP078E EP078E EP078E EP085 EP085 EP085 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 EP086 Document Control Desk PLA-6922 In-Plant Team Management Training I Retraining 811612012 Near Site Monitoring Training I Retraining 711212012 Near Site Monitoring Training I Retraining 713112012 Near Site Monitoring Training I Retraining 21812011 Near Site Monitoring Training I Retraining 611312011 Near Site Monitoring Training I Retraining 711212012 Near Site Monitoring Training I Retraining 101212012 Near Site Monitoring Training I Retraining 511712011 Severe Accident Progression and Phenomena 711412011 Severe Accident Progression and Phenomena 1012812011 Severe Accident Progression and Phenomena 41212012 Damage Support Procedures 1011512010 Damage Support Procedures 111912011 Damage Support Procedures 211712012 Damage Support Procedures 31212012 Damage Support Procedures 31912012 Damage Support Procedures 311612012 Damage Supj)ort Procedures 312012012 Damage Support Procedures 111912011 Damage Support Procedures 1113012011 Damage Support Procedures 211712012 Damage Support Procedures 311612012 Damage Support Procedures 312012012 Understanding Your Role in the Emergency Plan 811712011 Understanding Your Role in the Emergency Plan 4/1612012 Understanding Your Role in the Emergency Plan 512312012 Team Training 11412011 Team Training 112812011 Team Training 211712011 Team Training 312912011 Team Training 41412011 Team Training 711412011 Team Training 81412011 Team Training 8/1912011 Team Training 911612011 Team Training 912312011 Team Training 10/712011 Team Training 10/1412011 Team Training 10120/2011 Team Training 10121/2011 Team Training 1111112011 Team Training 1111512011 EP086 Team Training EP086 Team Training EP086 Team Training EP086 Team Training EP086 Team Training EP086 Team Training EP086 Team Training EP086 Team Training EP086 Team Training EP086 Team Training EP087 Computer Practices - MIDAS EP087 Computer Practices - MIDAS EP087 Computer Practices - MIDAS EP087 Computer Practices - MIDAS EP087 Computer Practices - MIDAS EP087 Computer Practices - MIDAS EP087 Computer Practices - MIDAS EP087 Computer Practices - MIDAS EP087 Computer Practices - MIDAS EP087 Computer Practices - MID AS EP091 Overview - Emergency Classifications EP091 Overview - Emergency Classifications EP091 Overview - Emergency Classifications EP092 Environmental Sampling Team Training EP092 Environmental Sampling Team Training EP092 Environmental Sampling Team Training EP098 PASS Training for Chemistry Coordinators EP098 PASS Training for Chemistry Coordinators EP099 PASS Training for Chemistry Coordinators EP099 PASS Training for Chemistry Coordinators EP101 EP-AD-028 NEP Staff Annual Training EP101 EP-AD-028 NEP Staff Annual Training EP101 EP-AD-028 NEP Staff Annual Training EP101 EP-AD-028 NEP Staff Annual Training EP101 EP-AD-028 NEP Staff Annual Training EP104 Operations Response to Terrorism EP104 Operations Response to Terrorism EP104 Operations Response to Terrorism EP104 Operations Response to Terrorism EP104 Operations Response to Terrorism EP104 Operations Response to Terrorism EP104 Operations Response to Terrorism Document Control Desk PLA-6922 12/9/2011 12/10/2011 12/22/2011 1/7/2012 1/25/2012 8/30/2012 9/6/2012 9/27/2012 10/8/2012 10/12/2012 12/7/2010 2/15/2011 3/8/2011 3/15/2011 1113/2011 1118/2011 11/15/2011 12/7/2011 12/14/2011 12115/2011 1/25/2011 4/5/2011 5/10/2012 10/2112010 10/13/2011 10/16/2012 5/31/2012 6/7/2012 5/3112012 6/7/2012 6/17/2011 12119/2011 1127/2012 1/30/2012 2114/2012 10/22/2010 11/22/2010 9/16/2011 10110/2011 9/18/2012 9/25/2012 10/3/2012 EP104 Operations Response to Terrorism EP104 Operations Response to Terrorism Document Control Desk PLA-6922 10/4/2012 10/9/2012 Table 5 - EP Courses Scheduled for the Onsite SSES Emergency Response Personnel from October 25, 2012 thru February 26, 2013 Course Number Course Name Date EP087 Computer Practices - MIDAS 10/25/2012 EP009R HP Level II & TSC Dose Calculator Retraining 10/25/2012 Dose Assessment& Protective Actions Training EP010 I Retraining 10/26/2012 EP087 Computer Practices - MIDAS 10/30/2012 EP009R HP Level II & TSC Dose Calculator Retraining 10/30/2012 EP087 Computer Practices - MIDAS 10/3112012 EP009R HP Level II & TSC Dose Calculator Retraining 10/3112012 EP009R HP Level II & TSC Dose Calculator Retraining 111112012 EP009R HP Level II & TSC Dose Calculator Retraining 1112/2012 EP087 Computer Practices - MIDAS 1115/2012 EP009R HP Level II & TSC Dose Calculator Retraining 1115/2012 EP087 Comg_uter Practices-MIDAS 1116/2012 EP009R HP Level II & TSC Dose Calculator Retraining 1116/2012 EP009R HP Level II & TSC Dose Calculator Retraining 11/7/2012 EP024R Post Accident Coolant Sample 11/7/2012 EP009R HP Level II & TSC Dose Calculator Retraining 11/8/2012 EP024R Post Accident Coolant Sample 1118/2012 EP087 Computer Practices - MIDAS 11/13/2012 EP009R HP Level II & TSC Dose Calculator Retraining 11/13/2012 EP009R HP Level II & TSC Dose Calculator Retraining 11114/2012 EP024R Post Accident Coolant Sample 11114/2012 EP087 Computer Practices - MIDAS 11115/2012 EP009R HP Level II & TSC Dose Calculator Retraining 11/15/2012 EP024R Post Accident Coolant Sample 11115/2012 EP009R HP Level II & TSC Dose Calculator Retraining 11/16/2012 EP009R HP Level II & TSC Dose Calculator Retraining 11120/2012 EP087 Computer Practices-MIDAS 12/4/2012 EP009R HP Level II & TSC Dose Calculator Retraining 12/4/2012 EP087 Computer Practices - MIDAS 12/6/2012 EP009R HP Level II & TSC Dose Calculator Retraining 12/6/2012 EP087 Comguter Practices - MIDAS 12/1112012 EP009R HP Level II & TSC Dose Calculator Retraining 12/11/2012 EP024R Post Accident Coolant Sample EP087 Computer Practices - MIDAS Document Control Desk PLA-6922 12/12/2012 12113/2012 EP009R HP Level II & TSC Dose Calculator Retraining 12/13/2012 EP024R Post Accident Coolant Sample 12/13/2012 EP024R Post Accident Coolant Sample 12/14/2012 Overview - Dose Assessment and Protective EP090 Actions 2/26/2013 Table 6 provides a list of training that was provided to municipalities located within the 1 0-mile Emergency Planning Zone (EPZ). The training focused on radiological emergencies within the EPZ as required by NRC NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
Table 6 - Offsite Municipality EP Training Date Municipal Training 5/8/2012 Union Township 5/14/2012 Slocum Township 5/17/2012 Conyngham Township 5/3112012 Beaver Township 6/6/2012 Fishing Creek Township 6/6/2012 Newport Township 6/19/2012 Sugarloaf Township 6/2112012 Hunlock Creek Township 711112012 North Centre Township 7/17/2012 Dorrance Township 8/13/2012 Butler/Conyngham Borough 8/13/2012 Nanticoke Township 8/15/2012 South Centre Township 8/16/2012 Berwick/Briar Creek Borough 8/20/2012 Salem Township 8/2112012 Nescopeck Township 8/22/2012 Shickshinny Township 8/23/2012 Black Creek Township 8/27/2012 Mifflinville Township 9/4/2012 Briar Creek Township 10/9/2012 Hollenback Township 10/10/2012 Nescopeck Borough 10/10/2012 Nuangola Borough Document Control Desk PLA-6922 Table 7 provides a list of training provided to the offsite emergency responders from the risk and support counties. The training focused on county radiological response teams and county radiation officers.
Table 7 - Offsite County Emergency Responder Training Date(s)
County Training 1113/2012, Columbia County Radiological Response 1/20/2012 Team 2/3/2012, Columbia County Initial Radiation Officer 2110/2012 2/8/2012 SCI Retreat Radiological Response Team 3/15/2012, Northumberland County Radiological 3/22/2012 Response Team 411112012 Lycoming County Radiological Response Team 4/19/2012 Schuylkill County Pottsville Radiological Response Team 5/9/2012 Lycoming County Radiation Officer 4/26/2012, Schuylkill County Mahoney City Radiological 5117/2012 Response Team 5/15/2012 Schuylkill County Pottsville Radiation Officer 5/2112012 Mifflinville Radiological Response Team 7/10/2012, Sweet Valley Luzerne County Radiological 7/17/2012, Response Team 7/24/2012 8/26/2012 Union County Tabletop Exercise 10/11/2012 Lackawanna County Tabletop Exercise 10/17/2012, Wyoming County Radiological Response 10/18/2012 Team Table 8 lists additional training provided to the offsite emergency responders from the risk and support counties. The training focused on county radiological response teams and county radiation officers.
Document Control Desk PLA-6922 Table 8 - Miscellaneous Training for Offsite Emergency Responders Date Miscellaneous Training March2011 Municipal Offsite-Training I Conference (All Municipalities) 7/21/2011 Annual Government training for the support counties, risk counties, PEMA, FEMA, Red Cross, Department of Health and the Pennsylvania Department of Environmental Protection-Bureau of Radiation Protection 6/6/2012 Berwick Hospital Training 6/12/2012 Ambulance Training 6/14/2012 Geisinger Medical Center Training 7/26/2012 Annual Government training for the support counties, risk counties, PEMA, FEMA, Red Cross, Department of Health and the Pennsylvania Department of Environmental Protection-Bureau of Radiation Protection 9/6/2012 Municipal Radiological Training 9/12/2012 Municipal Practice Drill (South Centre did not participate)
- 3. This exemption request is consistent with the common defense and security:
The common defense and security are not affected by this exemption request.
This exemption requests NRC approval to extend the schedule for performing the onsite portion of the exercise until February 26, 2013 as a result of an unplanned, yet necessary Unit 1 outage. The onsite functions of SSES 's emergency organization have been evaluated since the 201 0 full participation biennial exercise.
Granting this exemption will maintain focus on nuclear safety and security; therefore, it is in the interest of common defense and security. Pursuant to 10 CFR 50.12( a)(2),
the NRC will consider granting an exemption from the regulation if special circumstances are present. This exemption request meets this requirement since special circumstances are present.
Additionally, the exemption would provide only temporary relief from the 10 CFR 50, Appendix E, Section IV.F.2.b requirements. The rescheduled onsite portion will be evaluated on February 26, 2013. All other functions will be performed and evaluated during the originally scheduled exercise on October 23, 2012.
Environmental Assessment Document Control Desk PLA-6922 Granting this exemption request will allow the onsite portion of the SSES biennial EP exercise to be conducted on February 26, 2013. Although the onsite functions were previously scheduled to be performed on October 23,2012, this schedule change would have no impact on the environment since any outdoor activity during the exercise is limited to minimal use of roads and highways. The proposed action would not significantly increase the probability or consequences of an accident, change the types or quantities of radiological effluents that may be released offsite, or result in a significant increase in public or occupational radiation exposure, since there would be no change to facility operations that could create a new accident or affect a previously analyzed accident or release path.
Since the proposed action would not have any adverse environmental effects, there are no alternatives available for reducing or avoiding adverse environmental effects. With regard to non-radiological impacts, no changes would be made to non-radiological plant effluents or activities that would adversely affect the environment. Therefore, no significant non-radiological impacts would be associated with the proposed action.
There are no federal permits, licenses, approvals or other entitlements which must be obtained in connection with the proposed action. The proposed action is not subject to any environmental quality standards or requirements imposed by federal, state, regional, or local agencies having responsibility for environmental protection.
Conclusion Based on the above information, PPL requests a one-time exemption from the requirements of 10 CFR 50 Appendix E, Section IV.F.2.b, to reschedule the onsite portion of the biennial SSES EP exercise until February 26, 2013. This requested exemption 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 described in 10 CFR 50.12(a)(2).