Home > Electronic Reading Room > Document Collections > Commission Documents > Commission Papers (SECY) > 2003 > SECY-03-0033

SECY-03-0033

March 7, 2003

• PURPOSE
• BACKGROUND
• DISCUSSION
• CONCLUSION
• COORDINATION
• RECOMMENDATION

PURPOSE:

To obtain the Commission's approval of the proposal of AmerGen Energy Company, LLC (AmerGen), to consolidate the Three Mile Island Unit 1 (TMI-1) emergency operations facility (EOF) into the combined EOF at Coatsville, Pennsylvania, for Peach Bottom Atomic Power Station (PBAPS) and Limerick Generating Station (LGS).

BACKGROUND:

In the past four years, a major consolidation has been taking place in the electric generating industry. Utilities have been combining and reducing redundant staff and facilities to achieve cost efficiencies. AmerGen and Exelon Generation Company, LLC (Exelon; co-owner of AmerGen) have been particularly active in this regard. For example, Exelon has consolidated all the Exelon EOFs in Illinois, and AmerGen recently added the Clinton site to the group of plants served by Exelon's Centralized EOF. AmerGen now wants to consolidate the EOF for TMI-1 with the EOF established by Exelon for PBAPS and LGS. AmerGen is the licensee for TMI-1, and Exelon is the licensee for PBAPS and LGS. TMI-1, PBAPS and LGS are all located in Pennsylvania. This request is part of an integrated AmerGen and Exelon plan to improve organizational emergency response.

In preparation for their April 2003 emergency preparedness exercise, on July 1, 2002, AmerGen requested NRC approval to consolidate the TMI-1 EOF into the combined EOF for LGS and PBAPS located in Coatesville, Pennsylvania. In its application, the licensee states that this consolidation is part of an integrated AmerGen and Exelon Generation Company plan to improve organizational emergency response. Under Section 50.54(q) of Title 10 of the Code of Federal Regulations, licensees can change their emergency plans without prior NRC approval, provided that the change does not decrease the effectiveness of the plan and the plan continues to meet the requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50. AmerGen's request could be seen as decreasing the effectiveness of the emergency plan since the combined EOF is 50 miles from TMI-1 and the current EOF is only about 12 miles away. Furthermore, Commission approval is required for an EOF relocated more than 25 miles from the nuclear plant. (The original distance of 20 miles, specified in Supplement 1 to NUREG-0737, was changed to 25 miles in SECY-96-170, dated September 18, 1996.)

DISCUSSION:

The issue for Commission consideration is whether integrating and relocating the TMI-1 EOF into the combined EOF for LGS and PBAPS would decrease the effectiveness of the TMI-1 emergency response capability. The current combined EOF for LGS and PBAPS has been in operation since 1992. The Region I staff has observed the operation of this combined EOF in many exercises and concluded that the facility, including its structure, layout, equipment and supplies, were sufficient for it to function adequately. The only concerns are whether the addition of TMI-1 to the combined EOF would impact the operation of the EOF for the other sites and whether the licensee could activate this remote site in a timely manner, staff the facility with knowledgeable people, and communicate effectively with the TMI-1 site.

As part of the evaluation and review of the proposal to consolidate and move the TMI-1 EOF to the combined EOF located in Coatsville, Pennsylvania, an emergency preparedness specialist from NRC headquarters and the TMI-1 project manager visited the current TMI-1 EOF and the combined EOF on August 8, 2002. The visit provided an opportunity to discuss several issues regarding the move, as well as observe the physical facilities. In addition, on September 20, 2002, the licensee submitted responses to a Request for Additional Information. Information gained from the site visit and the written responses was used in developing the NRC staff's recommendation on this issue.

The staff considered the following factors in determining whether AmerGen's proposal to integrate the TMI-1 EOF with the combined EOF would decrease the effectiveness of the emergency plan.

Federal, State and Local Agreement: An EOF has several key emergency response functions. One function is coordinating the offsite response with state and local authorities. The state and local authorities usually send representatives to the EOF to meet face to face with licensee personnel and Federal officials. However, in Pennsylvania, only the state sends representatives to the EOF. The local authorities operate from their own emergency centers and do not travel to the licensee's EOF. Communications between the EOF and the local emergency centers are discussed later in the paper. AmerGen has obtained a letter from Pennsylvania, the affected state, approving the proposed consolidation of the EOFs. The Federal Emergency Management Agency has reviewed this Commission paper and has no objection.

Staffing and Training: The personnel staffing the Coatsville EOF will come from the Exelon Corporate Office in Kennett Square, Pennsylvania, to activate the EOF for an event at TMI-1 just as they do for an event at LGS or PBAPS. The licensee has stated that the corporate Kennett Square emergency response organization (ERO) EOF personnel will be required to complete TMI-1 specific systems training. The EOF responders will be augmented with staff having TMI-1 operational knowledge. These additional individuals are not required to be available within 60 minutes of the declaration of the event. However, technical support will also be available from the Technical Support Center through the various communication links discussed below.

Communication: Effective communication among site personnel, responders, and offsite support agencies is a key to the success of the combined EOF. AmerGen has committed to provide the same level of communication with TMI-1 as Exelon has provided for PBAPS and LGS. This includes a dedicated phone switch, backup radio links, and commercial telephone lines. The licensee has installed Emergency Preparedness private branch exchange (PBX) lines in the proposed combined EOF via independent T-1 lines.

Potential Overloading of the Combined EOF If Emergencies Occur Simultaneously at Two or More Facilities: The addition of a third site for the combined EOF increases the possibility the combined EOF might have to deal with two emergencies at the same time. In response to this issue AmerGen stated that the physical structure of the combined EOF, the equipment for displaying plant information and communicating with monitoring teams, as well as offsite agencies, are all capable of handling high work-loads associated with multiple events. AmerGen stated in its letter dated September 20, 2002, that it will conduct a drill once the facility is in operation to demonstrate that the combined EOF staff and equipment can function under these circumstances. In the letter dated January 16, 2003, the licensee committed to conduct this drill within calendar year 2003. NRC staff will observe the drill.

CONCLUSION:

The Nuclear Regulatory Commission (NRC) staff concludes that there is reasonable assurance that public health and safety will be maintained in the event of an emergency at the TMI-1 plant or at PBAPS and LGS with the integration of the TMI-1 EOF into the combined EOF for PBAPS and LGS. The NRC staff also concludes that the integration of the TMI-1 EOF into the combined EOF will not reduce the effectiveness of the emergency response capability for any of the three sites. The proposal to consolidate the TMI-1 EOF into the combined EOF is a reasonable action for AmerGen, since the combined EOF is already operating and has adequately fulfilled its function for PBAPS and LGS since 1992.

COORDINATION:

The Office of the General Counsel has reviewed this Commission paper and has no legal objection to its content. The Office of the Chief Financial Officer has reviewed this paper for resource implications and has no objection.

RECOMMENDATION:

Based upon the NRC staff's conclusion that there is reasonable assurance that public health and safety will be maintained in the event of an emergency at the TMI-1 plant with the integration of the TMI-1 EOF into the combined EOF, the NRC staff recommends that the Commission approve the relocation of the TMI-1 EOF and its integration into the combined EOF serving PBAPS and LGS.

Privacy Policy | Site Disclaimer
Thursday, February 22, 2007