ML15309A131

Supplemental Response for License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel

ML15309A131
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna
Issue date:	11/04/2015
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML15309A131 (11)

Text

200 Exelon Way Exelon Generation Kennett Square. PA 19348 www.exeloncorp.com November 4, 2015 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 10 CFR 50.90 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Calvert Cliffs Independent Spent Fuel Storage Installation Materials License No. SNM-2505 Docket No. 72-8 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220, 50-410, and 72-1036 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket Nos. 50-244 and 72-67

Subject:

Supplemental Response for License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel

Reference:

Letter from James Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel," dated July 29, 2015 By letter dated July 29, 2015 (Reference), Exelon Generation Company, LLC (Exelon) submitted the subject License Amendment Request (LAR) for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Nine Mile Point Nuclear Station, Units 1 and 2, and the R. E. Ginna Nuclear Power Plant.

The proposed changes would revise the description for Emergency Response Organization (ERO) requalification training frequency defined in Exelon's governing Emergency Plans for the named stations from annually to "once per calendar year not to exceed 18 months between training sessions."

U.S. Nuclear Regulatory Commission License Amendment Request - Supplemental Response Revise Emergency Plan Requalification Training Frequency November 4, 2015 Page 2 Subsequently, it was determined that the marked-up pages included an annotation on the top of the page indicating "Exelon Confidential/Proprietary" information. Exelon typically submits emergency preparedness related information (e.g., Emergency Plan and associated implementing procedures changes) pursuant to 1 O CFR 2.390 requesting that the information be withheld from public disclosure. However, the marked-up pages submitted in support of this LAR are not considered to be of a confidential/proprietary nature. Therefore, the marked-up pages are being resubmitted with the annotation removed. There are no other changes to the marked-up pages. The attachment to this submittal includes the updated marked-up pages for each affected facility's Emergency Plan.

Exelon has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of the July 29, 2015, letter (Reference). Exelon has concluded that the information provided in this response does not affect the bases for concluding that the proposed LAR does not involve a significant hazards consideration under the standards set forth in 1 O CFR 50.92. In addition, Exelon has concluded that the information in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed LAR.

There are no regulatory commitments contained in this submittal.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of Maryland and the State of New York of this application for license amendments by transmitting a copy of this letter and its supporting attachments to the designated state officials.

Should you have any questions regarding this submittal, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of November 2015.

~erfcttu11y, Ir Li("-~ I. A--J y---

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Exelon Nuclear Radiological Emergency Plan Station Annex - Updated Marked-up Pages cc:

Regional Administrator - NRC Region I NRC Senior Resident Inspector - Calvert Cliffs NRC Senior Resident Inspector - Nile Mile Point w/ Attachment

U.S. Nuclear Regulatory Commission License Amendment Request - Supplemental Response Revise Emergency Plan Requalification Training Frequency November 4, 2015 Page 3 cc: (continued)

NRG Senior Resident Inspector - R. E. Ginna NRG Project Manager, NRR - Exelon Fleet NRG Project Manager, NRR - Calvert Cliffs NRG Project Manager, NRR - Nile Mile Point NRG Project Manager, NRR - R.E. Ginna S. T. Gray, State of Maryland A. L. Peterson, NYSERDA w/ Attachment

ATTACHMENT Exelon Nuclear Radiological Emergency Plan Station Annex - Updated Marked-up Pages

Exelon Nuclear Radiological Emergency Plan Annex for Calvert Cliffs Station Marked-up Emergency Plan Pages cc 6-1

Calvert Cliffs Annex Exelon Nuclear Section 6: Maintaining Nuclear Emergency Preparedness 6.1 Training An integrated training program provides for and ensures initial, annual, and continuing training of appropriate individuals and groups involved in emergencies.

6.1.1 General Orientation General Employee Training describes the program that provides training to all persons having access to Calvert Cliffs Nuclear Power Plant and includes Emergency Plan indoctrination.

6.1.2 Emergency Personnel Plant procedures establish a training program for instructing personnel who implement radiological emergency plans. Specialized initial training, annual, and continuing training programs (including scope, nature and frequency) is provided for:

1. Directors or coordinators of response organizations.

2. Personnel responsible for accident assessment.

3. Radiological monitoring teams and radiological analysis personnel.

4. Security and fire fighting personnel.

5. On-site repair and damage control/correctional action teams.

6. First aid and rescue personnel. This training includes courses equivalent to or exceeding Red Cross Multi-Media.

7. Local support services personnel including Emergency ManagemenUEmergency Services personnel.

Site specific training is provided to those off-site organizations who may be called upon to provide assistance.

8. Medical support personnel.

9. Recovery Organization personnel.

10. Personnel responsible for transmission of emergency information instructions.

The 6.1.3 Public Annual requalification training as applied to those personnel assigned

1. Calvert Cliffs Exelon ERO positions is defined as once per calendar year not to exceed dissemination of 18 months between training sessions. The training program for members what their actio of the emergency organizations includes practical drills in which individuals not necessarily I demonstrate ability to petform assigned emergency functions. The training

. frequency for the practical drills is at least once every 2 years.

April 2015

a. Educational lt'rTcJ'TTTlrcrn-CJTT-an-n::sUTCl"n'<7rr.--------------------'

b. Contact for additional information.

c. Protective measures, e.g., evacuation routes and reception centers, sheltering, respiratory protection, radioprotective drugs.

cc 6-1 EP-AA-1011 (Revision 0)

Exelon Nuclear Radiological Emergency Plan Annex for Nine Mile Point Station Marked-up Emergency Plan Pages Pages NM 6-11 NM 6-12

Nine Mile Point Annex FIGURE 6.2 INITIAL TRAINING AND PERIODIC RETRAINING*

Emergency Response Exelon Nuclear

( Once per calendar year not to exceed 18 months between training sessions.

Category Involved Personnel (Typical)

Initial Training and Periodic Retraining

1.

Emergency Plan Persons granted unescorted access to the Initial - Emergency Plan content and implementation; Indoctrination Protected Area specifically: personal actions, warnings, assembly areas, use of station communications, personnel accountability and evacuation to an offsite assembly area.

2.

Emergency Directors/ ERF Plant Manager; Managers of Operations, SMs.

Initial - Instruction on the scope, responsibilities, and function of

3.

4.

Coordinators Initial responders, and others as designated the Emergency Plan and Implementing Procedures. including Incident Command System {ICS) concepts, position titles and terminology.

Personnel responsible for accident assessment and/or accident management Radiological Monitoring

/Analysis personnel February 2015 SM/Emergency Director and the Emergency Director at EOF, TSC, OSC and EOF Managers; and Alternates Radiation Management Supervisors. Radiation Protection Technicians, and others as designated NM 6-11 Initial - Instruction on the NMPNS Emergency Plan and Implementing Procedures and Technical Support Guidelines germane to their particular assessment/management function, including Incident Command System (!CS} concepts, position titles and terminology.

Periodic - Retraining will b~:~~~ ~~

a review of the above material an last training period.

Selected Radiation Protection personnel receive substantial training in radiation monitoring.

Initial - Training for personnel performing radiation monitoring and analysis duties will consist of instruction in the downwind and/or in plant radiation monitoring and sampling Implementing Procedures, including Incident Command System (ICS) concepts, position titles and terminology.

Periodic - Retraining will b~ith hands-on instrumentation usage including interpretation of results.

EP-AA-1013 (Revision 0)

Nine Mile Point Annex Exelon Nuclear FIGURE 6.2 (Cont.)

INITIAL TRAINING AND PERIODIC RETRAINING*

Emergency Response Category

!nv()lveqPersonn~flypical)

Initial Training and Periodic Retraining

5.

6.

Fire Response /First Aid/Rescue/Medical Support Damage Control/Repair Teams personnel

7.

Security Personnel/Local Law Enforcement Officials

8.

Communication Personnel NMPNS Fire Brigade/Offsite Fire Departments Ambulance and Hospital Personnel Nuclear Operators, Nuclear Auxiliary Operators. Maintenance Supervision, l&C Supervision, Radiation Protection Supervision Selected Maintenance, l&C and Radiation Protection Personnel, and others as designated Security personnel assigned responsibilities for Emergency Plan function, and Local Law Enforcement Officials.

As designated Designated members will receive training as appropriate in basic patient care and treatment. Members will also be instructed on the availability of onsite medical treatment supplies and equipment; communication systems; access controls radiological hazards; and roles, interfaces and responsibilities with local fire/

medical support personnel, including Incident Command System (ICS) concepts, position titles and terminology.

Repair and Damage Control are considered a normal part of the job functions of the listed personnel and, as such, special training in these functions, other than appropriate emergency plan and procedures training, is not required.

Training and retraining requirements are outlined in the Nine Mile Point Nuclear Security Training and Qualification Plan.

including Incident Command System (ICS) concepts. position titles and terminology.

Initial - Training shall consist of a review of appropriate Implementing Procedures, communications equipment and messages, including Incident Command System (ICS) concepts, position titles and terminology.

once per calendar year not to exceed 18 months between training sessions.

February 2015 NM 6-12 EP-AA-1013 (Revision 0)

Exelon Nuclear Radiological Emergency Plan Annex for Ginna Nuclear Station Marked-up Emergency Plan Pages GN 6-1

Ginna Annex Exelon Nuclear Section 6: Maintaining Nuclear Emergency Preparedness Formalized training program(s) have been established to ensure that all personnel who actively participate in the Nuclear Emergency Plan maintain their familiarity with the plan and their required response. A radiation emergency exercise shall be conducted at least annually, with emphasis placed upon orderly implementation of the emergency plan.

It is the Company management's expectation that responders will respond immediately upon being notified and not wait for additional time. This expectation is reinforced as part of the responder training.

Personnel trained for onsite response to a radiation emergency are part of the regular plant staff and are trained to specific responsibilities within the emergency organization.

Training is documented by the Manager, Emergency Preparedness and the Emergency Preparedness Staff. Any emergency plan work by consultants will be under the control of, and reviewed by, the Manager, Emergency Preparedness.

Exercises shall be evaluated by the Manager, Emergency Preparedness and reviewed by the Emergency Preparedness Station and Corporate Management, thereby assuring the effectiveness of the plan throughout the lifetime of the R. E. Ginna facility.

6.1 Training and Drills:

Provisions must be made to start a drill or exercise between 6:00 p.m. and 4:00 a.m. at least once in every eight-year cycle. Some drills or exercises should be unannounced.

Specialized training will be provided for:

1.

Technical Support Center assignees

2.

Operations Support Center assignees

3.

First Aid Teams

4.

Offsite Monitoring Teams

5.

Emergency Operations Facility personnel

6.

Security personnel

7.

Local Emergency Support Services personnel

8.

Fire Brigade personnel

9.

Dose Assessment personnel

10.

Core Damage Assessment personnel February 2015 GN 6-1 EP-AA-1012 (Revision 0)

200 Exelon Way Exelon Generation Kennett Square. PA 19348 www.exeloncorp.com November 4, 2015 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 10 CFR 50.90 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Calvert Cliffs Independent Spent Fuel Storage Installation Materials License No. SNM-2505 Docket No. 72-8 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220, 50-410, and 72-1036 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket Nos. 50-244 and 72-67

Subject:

Supplemental Response for License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel

Reference:

Letter from James Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel," dated July 29, 2015 By letter dated July 29, 2015 (Reference), Exelon Generation Company, LLC (Exelon) submitted the subject License Amendment Request (LAR) for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Nine Mile Point Nuclear Station, Units 1 and 2, and the R. E. Ginna Nuclear Power Plant.

The proposed changes would revise the description for Emergency Response Organization (ERO) requalification training frequency defined in Exelon's governing Emergency Plans for the named stations from annually to "once per calendar year not to exceed 18 months between training sessions."

U.S. Nuclear Regulatory Commission License Amendment Request - Supplemental Response Revise Emergency Plan Requalification Training Frequency November 4, 2015 Page 2 Subsequently, it was determined that the marked-up pages included an annotation on the top of the page indicating "Exelon Confidential/Proprietary" information. Exelon typically submits emergency preparedness related information (e.g., Emergency Plan and associated implementing procedures changes) pursuant to 1 O CFR 2.390 requesting that the information be withheld from public disclosure. However, the marked-up pages submitted in support of this LAR are not considered to be of a confidential/proprietary nature. Therefore, the marked-up pages are being resubmitted with the annotation removed. There are no other changes to the marked-up pages. The attachment to this submittal includes the updated marked-up pages for each affected facility's Emergency Plan.

Exelon has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of the July 29, 2015, letter (Reference). Exelon has concluded that the information provided in this response does not affect the bases for concluding that the proposed LAR does not involve a significant hazards consideration under the standards set forth in 1 O CFR 50.92. In addition, Exelon has concluded that the information in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed LAR.

There are no regulatory commitments contained in this submittal.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of Maryland and the State of New York of this application for license amendments by transmitting a copy of this letter and its supporting attachments to the designated state officials.

Should you have any questions regarding this submittal, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of November 2015.

~erfcttu11y, Ir Li("-~ I. A--J y---

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Exelon Nuclear Radiological Emergency Plan Station Annex - Updated Marked-up Pages cc:

Regional Administrator - NRC Region I NRC Senior Resident Inspector - Calvert Cliffs NRC Senior Resident Inspector - Nile Mile Point w/ Attachment

U.S. Nuclear Regulatory Commission License Amendment Request - Supplemental Response Revise Emergency Plan Requalification Training Frequency November 4, 2015 Page 3 cc: (continued)

NRG Senior Resident Inspector - R. E. Ginna NRG Project Manager, NRR - Exelon Fleet NRG Project Manager, NRR - Calvert Cliffs NRG Project Manager, NRR - Nile Mile Point NRG Project Manager, NRR - R.E. Ginna S. T. Gray, State of Maryland A. L. Peterson, NYSERDA w/ Attachment

ATTACHMENT Exelon Nuclear Radiological Emergency Plan Station Annex - Updated Marked-up Pages

Exelon Nuclear Radiological Emergency Plan Annex for Calvert Cliffs Station Marked-up Emergency Plan Pages cc 6-1

Calvert Cliffs Annex Exelon Nuclear Section 6: Maintaining Nuclear Emergency Preparedness 6.1 Training An integrated training program provides for and ensures initial, annual, and continuing training of appropriate individuals and groups involved in emergencies.

6.1.1 General Orientation General Employee Training describes the program that provides training to all persons having access to Calvert Cliffs Nuclear Power Plant and includes Emergency Plan indoctrination.

6.1.2 Emergency Personnel Plant procedures establish a training program for instructing personnel who implement radiological emergency plans. Specialized initial training, annual, and continuing training programs (including scope, nature and frequency) is provided for:

1. Directors or coordinators of response organizations.

2. Personnel responsible for accident assessment.

3. Radiological monitoring teams and radiological analysis personnel.

4. Security and fire fighting personnel.

5. On-site repair and damage control/correctional action teams.

6. First aid and rescue personnel. This training includes courses equivalent to or exceeding Red Cross Multi-Media.

7. Local support services personnel including Emergency ManagemenUEmergency Services personnel.

Site specific training is provided to those off-site organizations who may be called upon to provide assistance.

8. Medical support personnel.

9. Recovery Organization personnel.

10. Personnel responsible for transmission of emergency information instructions.

The 6.1.3 Public Annual requalification training as applied to those personnel assigned

1. Calvert Cliffs Exelon ERO positions is defined as once per calendar year not to exceed dissemination of 18 months between training sessions. The training program for members what their actio of the emergency organizations includes practical drills in which individuals not necessarily I demonstrate ability to petform assigned emergency functions. The training

. frequency for the practical drills is at least once every 2 years.

April 2015

a. Educational lt'rTcJ'TTTlrcrn-CJTT-an-n::sUTCl"n'<7rr.--------------------'

b. Contact for additional information.

c. Protective measures, e.g., evacuation routes and reception centers, sheltering, respiratory protection, radioprotective drugs.

cc 6-1 EP-AA-1011 (Revision 0)

Exelon Nuclear Radiological Emergency Plan Annex for Nine Mile Point Station Marked-up Emergency Plan Pages Pages NM 6-11 NM 6-12

Nine Mile Point Annex FIGURE 6.2 INITIAL TRAINING AND PERIODIC RETRAINING*

Emergency Response Exelon Nuclear

( Once per calendar year not to exceed 18 months between training sessions.

Category Involved Personnel (Typical)

Initial Training and Periodic Retraining

1.

Emergency Plan Persons granted unescorted access to the Initial - Emergency Plan content and implementation; Indoctrination Protected Area specifically: personal actions, warnings, assembly areas, use of station communications, personnel accountability and evacuation to an offsite assembly area.

2.

Emergency Directors/ ERF Plant Manager; Managers of Operations, SMs.

Initial - Instruction on the scope, responsibilities, and function of

3.

4.

Coordinators Initial responders, and others as designated the Emergency Plan and Implementing Procedures. including Incident Command System {ICS) concepts, position titles and terminology.

Personnel responsible for accident assessment and/or accident management Radiological Monitoring

/Analysis personnel February 2015 SM/Emergency Director and the Emergency Director at EOF, TSC, OSC and EOF Managers; and Alternates Radiation Management Supervisors. Radiation Protection Technicians, and others as designated NM 6-11 Initial - Instruction on the NMPNS Emergency Plan and Implementing Procedures and Technical Support Guidelines germane to their particular assessment/management function, including Incident Command System (!CS} concepts, position titles and terminology.

Periodic - Retraining will b~:~~~ ~~

a review of the above material an last training period.

Selected Radiation Protection personnel receive substantial training in radiation monitoring.

Initial - Training for personnel performing radiation monitoring and analysis duties will consist of instruction in the downwind and/or in plant radiation monitoring and sampling Implementing Procedures, including Incident Command System (ICS) concepts, position titles and terminology.

Periodic - Retraining will b~ith hands-on instrumentation usage including interpretation of results.

EP-AA-1013 (Revision 0)

Nine Mile Point Annex Exelon Nuclear FIGURE 6.2 (Cont.)

INITIAL TRAINING AND PERIODIC RETRAINING*

Emergency Response Category

!nv()lveqPersonn~flypical)

Initial Training and Periodic Retraining

5.

6.

Fire Response /First Aid/Rescue/Medical Support Damage Control/Repair Teams personnel

7.

Security Personnel/Local Law Enforcement Officials

8.

Communication Personnel NMPNS Fire Brigade/Offsite Fire Departments Ambulance and Hospital Personnel Nuclear Operators, Nuclear Auxiliary Operators. Maintenance Supervision, l&C Supervision, Radiation Protection Supervision Selected Maintenance, l&C and Radiation Protection Personnel, and others as designated Security personnel assigned responsibilities for Emergency Plan function, and Local Law Enforcement Officials.

As designated Designated members will receive training as appropriate in basic patient care and treatment. Members will also be instructed on the availability of onsite medical treatment supplies and equipment; communication systems; access controls radiological hazards; and roles, interfaces and responsibilities with local fire/

medical support personnel, including Incident Command System (ICS) concepts, position titles and terminology.

Repair and Damage Control are considered a normal part of the job functions of the listed personnel and, as such, special training in these functions, other than appropriate emergency plan and procedures training, is not required.

Training and retraining requirements are outlined in the Nine Mile Point Nuclear Security Training and Qualification Plan.

including Incident Command System (ICS) concepts. position titles and terminology.

Initial - Training shall consist of a review of appropriate Implementing Procedures, communications equipment and messages, including Incident Command System (ICS) concepts, position titles and terminology.

once per calendar year not to exceed 18 months between training sessions.

February 2015 NM 6-12 EP-AA-1013 (Revision 0)

Exelon Nuclear Radiological Emergency Plan Annex for Ginna Nuclear Station Marked-up Emergency Plan Pages GN 6-1

Ginna Annex Exelon Nuclear Section 6: Maintaining Nuclear Emergency Preparedness Formalized training program(s) have been established to ensure that all personnel who actively participate in the Nuclear Emergency Plan maintain their familiarity with the plan and their required response. A radiation emergency exercise shall be conducted at least annually, with emphasis placed upon orderly implementation of the emergency plan.

It is the Company management's expectation that responders will respond immediately upon being notified and not wait for additional time. This expectation is reinforced as part of the responder training.

Personnel trained for onsite response to a radiation emergency are part of the regular plant staff and are trained to specific responsibilities within the emergency organization.

Training is documented by the Manager, Emergency Preparedness and the Emergency Preparedness Staff. Any emergency plan work by consultants will be under the control of, and reviewed by, the Manager, Emergency Preparedness.

Exercises shall be evaluated by the Manager, Emergency Preparedness and reviewed by the Emergency Preparedness Station and Corporate Management, thereby assuring the effectiveness of the plan throughout the lifetime of the R. E. Ginna facility.

6.1 Training and Drills:

Provisions must be made to start a drill or exercise between 6:00 p.m. and 4:00 a.m. at least once in every eight-year cycle. Some drills or exercises should be unannounced.

Specialized training will be provided for:

1.

Technical Support Center assignees

2.

Operations Support Center assignees

3.

First Aid Teams

4.

Offsite Monitoring Teams

5.

Emergency Operations Facility personnel

6.

Security personnel

7.

Local Emergency Support Services personnel

8.

Fire Brigade personnel

9.

Dose Assessment personnel

10.

Core Damage Assessment personnel February 2015 GN 6-1 EP-AA-1012 (Revision 0)