POLICY ISSUE

NOTATION VOTE

March 7, 2003 SECY-03-0033

FOR: The Commissioners 

FROM: William D. Travers 

Executive Director for Operations 

SUBJECT: REVISED AMERGEN’S REQUEST TO CONSOLIDATE THE THREE MILE

ISLAND UNIT 1 EMERGENCY OPERATIONS FACILITY (EOF) INTO THE

COMBINED EOF FOR PEACH BOTTOM ATOMIC POWER STATION (PBAPS)

AND LIMERICK GENERATING STATION (LGS)

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 

CONTACT: Robert E. Moody, NRR

 415-1737
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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
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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. 
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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.

/RA/

William D. Travers 

Executive Director

 for Operations 
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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.

/RA/

William D. Travers 

Executive Director 

 for Operations 

ADAMS Accession Number:ML030650225 

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