ML20043A788
| ML20043A788 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/16/1990 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9005230127 | |
| Download: ML20043A788 (7) | |
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{{#Wiki_filter:l 10 CFR 50,12 l PHILADELPHIA ELECTRIC COMPANY I i NUCLEAR GROUP HEADQUARTERS l l 955 65 CHESTERBROOK BLVD. WAYNE. PA 19087 5691 (sts) s40 sooo May 16, 1990 , 1 Docket Nos. 50-352 i 50-353 License Nos. NPF-39 NPF ; U.S. Nuclear Regulatory Commission Attn: Document Control Desk , Wasnington,'DC 20555
SUBJECT:
Limerick Generating Station Units 1 and 2 Request for an Exemption from Holding a full Participation Onsite/Offsite Emergency Exercise During 1990 ( Ocar Sirs: Philadelphia Electric Company (PECo) is submitting this letter to request an exemption, in accordance with 50.12, from the requirement of 10 CFR 50 Appendix E.
" Emergency Planning and Preparedness for Production and Utilization Facilities " to perform a biennial full participation onsite/offsite emergency exercise at Limerick-l Generating Station (LGS), Units 1 and 2, during 1990.
Exemption Request
'We are requesting an exemption from the requirement to perform a biennial full participation onsite/offsite emergency exercise for LGS, Units 1 and 2 during 1990.
This exemption request, if approved, would provide only temporary relief from the requirement of 10 CFR 50 Appendix E. Section IV.F.3, which states in part: "Each licensee at each site-shall exercise with offsite authorities such that the State and local government emergency plans for each operating reactor site are exercised biennially, with full or_ partial participation by State and local governments, within the plume exposure pathway EPZ." The justification for this exemption request is provided below in accordance with 10 CFR 50.12. In addition, information is provided in accordance with 10 CFR 51.30 which supports the conclusion that the approval of this exemption request would not have an effect on the environment. F [ ffbb i j'2
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VoS Nuclear Regulatory Commission May 16, 1990
- Docume.nt Control Desk Page 2 '
l Justification for Exemption 10 CFR 50.12 permits the NRC to grant exemptions from the requirements in 10 CFR 50 for special circumstances as described in 10 CFR 50.12(a)(2). One such special , circumstance permits an exemption when: "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." In this case, a good faith effort has been made to comply with the requirement _as discussed below, and we are only requesting temporary relief from the regulation requiring a full participation onsite/offsite emergency exercise at LGS Units 1 and 2, during 1990. Since 1984, we have been conducting the required biennial full participation emergencyexercisesforbothLGSandthePeachBottomAtomicPowerStation(PBAPS) , during the same year. The last emergency exercise at LGS involving full participation of offsite agencies was conducted on April 5, 1988. We note that based on the results of this exercise, the NRC and the Federal Emergency Management Agency (FEMA) concluded that there was reasonable assurance that appropriate protective measures could be taken by both Philadelphia Electric Company and the State and local government agencies to protect public health and safety in the event of a radiological emergency at LGS. This practice of performing the LGS and PBAPS full participation exercises during the same year has caused logistical and resource utilization difficulties for us. Therefore, approval of this exemption request would alleviate the problems associated with conducting the exercises during the same year; thereby, enabling us t to better allocate resources and address the various non-exercise emergency preparedness issues that may arise for either facility both onsite and offsite.
- We intend to reschedule this emergency exercise for as early in 1991 as possible, taking into consideration various concerns of the NRC, FEMA, Commonwealth of Pennsylvania, and local government agencies. If-this exemption request is approved, the emergency exercise would be scheduled for a date between mid-January and mid-February of 1991. This would result in delaying the emergency exercise, which is currently scheduled for the week of September 17, 1990, for four (4) or five (5) months. All future full participation emergency exercises for LGS would be conducted on a biennial schedule from the date when the rescheduled exercise is performed. We have discussed our proposed schedule change with'the Pennsylvania Emergency Management Agency (PEMA), the three risk counties (Berks, Chester, and Montgomery), and two support counties (Bucks and Lehigh). Based on these discussions, these government agencies have not objected to rescheduling the full participation emergency exercise to 1991. Attached are letters from PEMA, Bucks County, Montgomery County, and Berks County documenting their concurrence.
Concurrence letters have not been received from Chester or Lehigh Counties; however, we have received verbal concurrence from those counties to reschedule the emergency exercise. If this exemption is approved, we plan to conduct a limited participation annual emergency exercise for LGS during the week of September 17, 1990, as currently scheduled. The State and local governments could still participate, at their option, although full participation from offsite government agencies would not be expected. Furthermore, we will continue to provide the necessary training to the appropriate State and local government emergency responders to ensure that we continue to maintain the same high level of preparedness.
U.S. Nuclear Regulatory Commission May 16, 1990 ;
/ Document Control Desk Page 3 Environmental Assessment Environmental Impact of the Proposed Action The biennial full participation onsite/offsite emergency exercise would not be conducted for LGS, Units 1 and 2 .during 1990, if the requested exemption is approved by the NRC. Whether or not the exercise is conducted, the environment is not impacted since neither case involves the release of radioactive or non-radioactive effluents. In addition, the NRC has determined that an environmental impact statement for 10 CFR 50 Appendix E, in which the requirement for conducting the biennial full participation emergency exercise is contained, was not required (45 FR 55402, August 19,1980).- Therefore, not conducting the biennial full participation emergency exercise as required by the regulation will not have an impact on the human environment.
Alternatives to the Proposed Action The previous section provides the basis for concluding that there are no environmental effects which would result from the approval of the requested exemption. Accordingly, any alternatives with any environmental impact need not be evaluated. Alternative Use of Resources This exemption request, if granted, does not involve the use of any resources not previously considered in the Final Environmental Impact Statement for LGS, Units 1 and 2. Proposed Finding of No Significant Impact Based upon the foregoing environmental assessment, we conclude that the approval of our exemption request will not have an effect on the quality of the human environment. If you have any questions, or require additional information, please do not hesitate to contact us. Very truly yours, if 1 - G. A. Hunger, Jr. Manager Licensing Section Nuclear Engineering and Services Attachments cc: T. T. Martin, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS 1 l-
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O g @ ., l PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY - P.O. BOX 3321 - 4 : p, 4 y ' - ' l i HARR!SBURG, PENNSYLVANIA 171054321 (th.n. w . ;
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Mr. Craig Adams . Director H- "' " _4 P"' A MHr> & #2 .:, Emergency Preparednesa Seetion -a,+o.~,,-.s.- . . + , ... .e r.;, . ~.. ~m a-m A s-~ ' Nuclear Support Division-Philadelphia Electric Company !
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955-65 Chesterbrook Boulevard , a Wayne,' Pennsylvania 19087-0194 Dear Mr.'Adamst In response to your April 5, 1990 letter, I concur that -the . current FEMA Region ITI cchedule whereby Philadelphia' Electric Company muct. i a v - conduct the required biennial exercise'. for both Limerick- and Pcad' Bot bi in the same year is indeed .neither desirable nor in the' best interest of, all concerned. j In order to remedy this situation, PEMA< supports your exemption j request to the NRC to move the currently scheduled Limerick Exercise froe September 1990 to early 1991. This will, however, necessitate moving the , scheduled 1991 SSES Exercise to later in the year v.hich could impact on the '; dates FEMA has established for the Calvert Cliffs and Surry Exercises. In '
, , view of thic, it is recommended that you consider requesting . movemene of '
tne Limerick Exercise to late January or early February 1991 rather than between mid-February and mid-March 1991 as proposed in your letter. , Si cerely,
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Joseph L. LaFleur 2HW2h M=h.i i Director i JLL/RJH/cs -
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. ANDREW L. WARREN. Chairman Coordinator .
MARK S. SCliWEIKER . <* LUCILLE M. TRENCil ' April 16,1990 tiarford'P. Drexler l'
'EMA Executive
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.C. L. Adarps , Director _,
Emergency Preparedness.Section-Nuclear Support Division Philadelphia Electric Company
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Dear Mr. Adams:
This is to advise that Bucks County holds a neutral position re-garding the' scheduling of the upcoming Limerick exercise. This is to say, l that I perceive no advantage nor disadvantage with either time frame.under discussion. Bucks County is prepared to put its support plans into effect l .at any time.. u,e . , . .m . , . . , ,,
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Sincerely.
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FloH1ANA M. SLOSS 3 RITA C. B ANNING 77 DEPARTMENT oF PUBLIC SAFETY OFFICE OF EMERGENCY PREPAREDNESS JostPH O. HAMILTON,0sRtCTOR 60 EAGLEVILLE ROAD e EAGLEVILLE, PENNSYLVANIA 19403 (21$) 631 6530
. A. LINDLEY ,DIGELOW, COORDINATOR ,,
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. Mr. Craig L. Adams, Director Emergency Preparedness Section Nuclear. Support Division philadelphia Electric' Company Nuclear Group Headquarters 455-65 Chesterbrook Blvd. . .
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Dear Craig:
Reference is made to your correspondence of April 5, 1990, concerning our earlier discussions of the possibility of moving the full participation Limerick exercise, currently scheduled for September 20, 1990, into 1991. ,
... Montgomery County has-no objection-to changing the acts i,i the next Limerick full participation exercise to early-1991, providing approval is obtained from the NRC.
Very truly yours, e
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CICHAEL F. FEENEY . ROBERT L. REBER ~ ANTHONY J. CARABELLO. -
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'CLENN B. REBER
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BERKS COUNTY EMERGENCY MANAGEMENT AGENCY
$ERN 1WP. AGRICULTURAL CENTER. R.D.1. LtEsPoRT. PA 19533 (715) 374 4800
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l In response to your letter of April 5, 1990 with regard to-the possibility of rescheduling the September Limerick drill,which we also discussed during our Chesterbrook meeting, I have no problem with either date. We are preparing for a September 1990 exercise, but moving it to early 1991 will pose no problems. -
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, Robert L. Reber Director
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