ML070120260
| ML070120260 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Oyster Creek, Hope Creek, Byron, Braidwood, Limerick, Clinton, Quad Cities, LaSalle, Crane |
| Issue date: | 01/17/2007 |
| From: | Gratton C NRC/NRR/ADRO/DORL/LPLIII-2 |
| To: | Crane C Exelon Generation Co |
| Gratton C, NRR/DORL, 415-1055 | |
| References | |
| TAC LS2697, TAC MD2846, TAC MD2847, TAC MD2848, TAC MD2849, TAC MD2850, TAC MD2851, TAC MD2852, TAC MD2853, TAC MD2854, TAC MD2855, TAC MD2856, TAC MD2857, TAC MD2858, TAC MD2859, TAC MD2860, TAC MD2861, TAC MD2862 | |
| Download: ML070120260 (19) | |
Text
January 17, 2007 Christopher M. Crane President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; OYSTER CREEK NUCLEAR GENERATING STATION; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; AND THREE MILE ISLAND NUCLEAR STATION, UNITS 1 AND 2 - REVISION OF EMERGENCY ACTION LEVELS IN RADIOLOGICAL EMERGENCY RESPONSE PLAN (TAC NOS. MD2846 THROUGH MD2862, AND LS2697)
Dear Mr. Crane:
By letter dated August 15, 2006, and supplemented by letters dated December 1, and December 14, 2006, Exelon Generation Company, LLC, and AmerGen Energy Company, LLC, (Exelon/AmerGen), requested prior Nuclear Regulatory Commission (NRC) approval for changes to the emergency action levels (EALs) for the following stations: Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Station, Units 1 and 2; and Three Mile Island Nuclear Station, Units 1 and 2 (TMI).
Subsequent to Exelon/AmerGens December 1, 2006, supplemental response, Exelon/AmerGen informed the staff during a teleconference on December 13, 2006, that they intend to supplement the EAL submittal for TMI. Exelon/AmerGen followed that notification with an e-mail on December 14, 2006, reiterating their intent to supplement the TMI submittal.
Therefore, this letter does not address TMI.
The changes to the EALs support a conversion from an EAL scheme currently based on NUMARC/NESP-007, Revision 2, Methodology for Development of Emergency Action Levels to a scheme based on NEI 99-01, Methodology for Development of Emergency Action Levels (Revision 4, January 2003), in accordance with Regulatory Issue Summary 2003-18, with Supplements 1 and 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels.
As discussed in the enclosed safety evaluation, the Commission concludes that the EAL changes proposed herein meet the standards of 10 CFR 50.47(b) and the requirements of Section IV.B of Appendix E to 10 CFR Part 50, and are, therefore, acceptable.
Sincerely,
/RA/
Christopher Gratton, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456 and STN 50-457; STN 50-454 and STN 50-455; 50-461; 50-237, and 50-249; 50-373 and 50-374; 50-352 and 50-353; 50-219; 50-277 and 50-278; 50-254 and 50-265; 50-289; and 50-320
Enclosure:
Safety Evaluation cc w/encl: See next page
ML070120260 OFFICE NRR/LPL3-2/PM NRR/LPL3-2/LA NSIR/LRB NSIR/LRB/BC NRR/LPL3-2/BC NAME CGratton EWhitt DJohnson EWeiss MMarshall DATE 1/17/07 1/17/07 1/12/07 1/12/07 1/17/07
Byron/Braidwood Stations cc:
Dwain W. Alexander, Project Manager Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355 Pittsburgh, PA 15230-0355 Howard A. Learner Environmental Law and Policy Center of the Midwest 35 East Wacker Dr., Suite 1300 Chicago, IL 60601-2110 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 N. German Church Road Byron, IL 61010-9750 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Chairman, Ogle County Board Post Office Box 357 Oregon, IL 61061 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, IL 61107 Attorney General 500 S. Second Street Springfield, IL 62701 Illinois Emergency Management Agency Division of Disaster Assistance &
Preparedness 110 East Adams Street Springfield, IL 62701-1109 Plant Manager - Byron Station Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Site Vice President - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office 35100 S. Rt. 53, Suite 79 Braceville, IL 60407 County Executive Will County Office Building 302 N. Chicago Street Joliet, IL 60432 Plant Manager - Braidwood Station Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Ms. Bridget Little Rorem Appleseed Coordinator 117 N. Linden Street Essex, IL 60935 Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Site Vice President - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Senior Vice President - Operations Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
Byron/Braidwood Stations cc:
Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Regulatory Assurance - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Manager Regulatory Assurance - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Vice President - Regulatory & Legal Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Braidwood/Byron Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President - Midwest Operations Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Clinton Power Station, Unit 1 cc:
Manager Regulatory Assurance - Clinton AmerGen Energy Company, LLC Clinton Power Station RR3, Box 228 Clinton, IL 61727-9351 Site Vice President - Clinton Power Station AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351 Plant Manager - Clinton Power Station AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351 Resident Inspector U.S. Nuclear Regulatory Commission RR #3, Box 229A Clinton, IL 61727 Chairman of DeWitt County c/o County Clerks Office DeWitt County Courthouse Clinton, IL 61727 J. W. Blattner Project Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago, IL 60603
Dresden and Quad Cities Nuclear Power Stations cc:
Site Vice President - Dresden Nuclear Power Station Exelon Generation Company, LLC 6500 N. Dresden Road Morris, IL 60450-9765 Plant Manager - Dresden Nuclear Power Station Exelon Generation Company, LLC 6500 N. Dresden Road Morris, IL 60450-9765 Manager Regulatory Assurance - Dresden Exelon Generation Company, LLC 6500 N. Dresden Road Morris, IL 60450-9765 U.S. Nuclear Regulatory Commission Dresden Resident Inspectors Office 6500 N. Dresden Road Morris, IL 60450-9766 Chairman Grundy County Board Administration Building 1320 Union Street Morris, IL 60450 Regional Administrator U.S. NRC, Region III 801 Warrenville Road Lisle, IL 60532-4351 Site Vice President - Quad Cities Exelon Generation Company, LLC 22710 206th Avenue N.
Cordova, IL 61242-9740 Plant Manager - Quad Cities Exelon Generation Company, LLC 22710 206th Avenue N.
Cordova, IL 61242-9740 Regulatory Assurance Manager - Quad Cities Exelon Generation Company, LLC 22710 206th Avenue N.
Cordova, IL 61242-9740 Quad Cities Resident Inspectors Office U.S. Nuclear Regulatory Commission 22712 206th Avenue N.
Cordova, IL 61242 David C. Tubbs MidAmerican Energy Company One River Center Place 106 E. Second, P.O. Box 4350 Davenport, IA 52808-4350 Vice President - Law and Regulatory Affairs MidAmerican Energy Company One River Center Place 106 E. Second Street P.O. Box 4350 Davenport, IA 52808 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.
Rock Island, IL 61201 LaSalle County Station, Units 1 and 2 cc:
Site Vice President - LaSalle County Station Exelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757 Plant Manager - LaSalle County Station Exelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757
LaSalle County Station, Units 1 and 2 cc:
Manager Regulatory Assurance - LaSalle Exelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757 U.S. Nuclear Regulatory Commission LaSalle Resident Inspectors Office 2605 North 21st Road Marseilles, IL 61341-9756 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, IL 60603 Assistant Attorney General 100 W. Randolph St. Suite 12 Chicago, IL 60601 Chairman LaSalle County Board 707 Etna Road Ottawa, IL 61350 Chairman Illinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706 Robert Cushing, Chief, Public Utilities Division Illinois Attorney General's Office 100 W. Randolph Street Chicago, IL 60601 Regional Administrator U.S. NRC, Region III 801 Warrenville Road Lisle, IL 60532-4351
Limerick Generating Station, Unit Nos. 1 and 2 cc:
Site Vice President Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Plant Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Senior Vice President - Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations, Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Manager Licensing Limerick Generating Station Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Director, Bureau of Radiation Protection Pennsylvania Dept. of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803
Oyster Creek Nuclear Generating Station Site Vice President - Oyster Creek Nuclear Generating Station AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Senior Vice President of Operations AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Kathryn M. Sutton, Esquire Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Manager Licensing - Oyster Creek Exelon Generation Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Regulatory Assurance Manager Oyster Creek AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Assistant General Counsel AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348 Ron Bellamy, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Correspondence Control Desk AmerGen Energy Company, LLC 200 Exelon Way, KSA 1--1 Kennett Square, PA 19348 Oyster Creek Nuclear Generating Station Plant Manager AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Site Vice President Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Plant Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Regulatory Assurance Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station P.O. Box 399 Delta, PA 17314 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Roland Fletcher Department of Environment Radiological Health Program 2400 Broening Highway Baltimore, MD 21224 Correspondence Control Desk Exelon Generation Company, LLC P. O. Box 160 Kennett Square, PA 19348 Director, Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Board of Supervisors Peach Bottom Township 545 Broad Street Ext.
Delta, PA 17314-9203 Mr. Richard McLean Power Plant and Environmental Review Division Department of Natural Resources B-3, Tawes State Office Building Annapolis, MD 21401 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Manager-Financial Control & Co-Owner Affairs Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236 Manager Licensing-Peach Bottom Atomic Power Station Exelon Generation Company, LLC 200 Exelon Way, KSA -3E Kennett Square, PA 19348
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President-Operations Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Senior Vice President, Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director-Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
Three Mile Island Nuclear Station, Unit 1 cc:
Site Vice President - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057 Senior Vice President - Nuclear Services AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations, Mid-Atlantic AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regional Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Chairman Board of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120 Chairman Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 Senior Resident Inspector (TMI-1)
U.S. Nuclear Regulatory Commission P.O. Box 219 Middletown, PA 17057 Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Plant Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057 Regulatory Assurance Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P.O. Box 480 Middletown, PA 17057 Ronald Bellamy, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Michael A. Schoppman Framatome ANP Suite 705 1911 North Ft. Myer Drive Rosslyn, VA 22209 Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101
Three Mile Island Nuclear Station, Unit 1 cc:
Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 Correspondence Control Desk AmerGen Energy Company, LLC P.O. Box 160 Kennett Square, PA 19348 Manager Licensing - Three Mile Island Nuclear Station, Unit 1 Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Assistant General Counsel AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO A PROPOSED REVISION TO THE EMERGENCY ACTION LEVELS FOR THE BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; OYSTER CREEK NUCLEAR GENERATING STATION; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. STN 50-456 AND STN 50-457; STN 50-454 AND STN 50-455; 50-461; 50-237, AND 50-249; 50-373 AND 50-374; 50-352 AND 50-353; 50-219; 50-277, AND 50-278; 50-254 AND 50-265
1.0 INTRODUCTION
By letter dated August 15, 2006 (Reference No. 1), supplemented by letters dated December 1, 2006 (Reference No. 2), and December 14, 2006 (Reference No. 3), Exelon Generation Company, LLC, and AmerGen Energy Company, LLC, (Exelon/AmerGen) requested prior Nuclear Regulatory Commission (NRC) approval for changes to the emergency action levels (EALs) for the following stations: Braidwood Station, Units 1 and 2 (Braidwood); Byron Station, Unit Nos. 1 and 2 (Byron); Clinton Power Station, Unit No. 1 (Clinton); Dresden Nuclear Station, Units 2 and 3 (Dresden); LaSalle County Station, Units 1 and 2 (LaSalle); Limerick Generating Station, Units 1 and 2 (Limerick); Oyster Creek Generating Station (Oyster Creek); Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom); Quad Cities Nuclear Station, Units 1 and 2 (Quad Cities); and Three Mile Island Nuclear Station, Units 1 and 2 (TMI).
Subsequent to Exelon/AmerGens December 1, 2006, supplemental response, Exelon/AmerGen informed the NRC staff during a teleconference on December 13, 2006, that they intend to supplement the TMI submittal. Exelon/AmerGen followed that notification with an e-mail (Reference No. 8) on December 14, 2006, reiterating their intent to supplement the TMI submittal. Therefore, this letter does not address TMI.
The requested changes to the licensees EALs supports a conversion from an EAL scheme currently based on NUMARC/NESP-007, Revision 2, Methodology for Development of Emergency Action Levels (Reference No. 4), to a scheme based on NEI 99-01, Methodology for Development of Emergency Action Levels (Revision 4, January 2003) (Reference No. 5), in accordance with Regulatory Issue Summary (RIS) 2003-18, with Supplements 1 and 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels (Reference No. 6).
These changes have been evaluated by Exelon/AmerGen to be an alternate method for complying with the regulations and have been submitted to the NRC for prior approval.
2.0 REGULATORY EVALUATION
The NRC staff reviewed the proposed revisions against the following regulations and guidance:
2.1 Regulations Paragraph (a)(1) to Section 50.47, Emergency Plans, of 10 CFR Part 50 states, in part, that no operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that the state of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Section 50.47 also establishes standards that must be met by the onsite and offsite emergency response plans for NRC staff to make a positive finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. One of these standards, 50.47(b)(4), stipulates that emergency plans include a standard emergency classification and action level scheme.
Section IV.B to Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, of 10 CFR Part 50 provides that emergency plans are to include EALs, which are to be used as criteria for determining the need for notification and participation of State and local agencies, and which are to be used for determining when and what type of protective measures should be considered both onsite and offsite to protect health and safety.
EALs are to be based on in-plant conditions and instrumentation, and also on onsite and offsite monitoring.Section IV.B of Appendix E provides that initial EALs shall be discussed and agreed on by the applicant and State and local authorities, and be approved by NRC, and reviewed annually thereafter with State and local authorities. In addition,Section IV.B of Appendix E states, in part, that an EAL revision must be approved by the NRC before implementation if it involves: (1) the changing from an EAL scheme based on NUREG-0654/FEMA-REP-1 to a scheme based on NUMARC/NESP-007 or NEI 99-01; (2) the licensee is proposing an alternate method for complying with the regulations; or (3) the EAL revision has been evaluated by licensee as constituting a decrease in effectiveness.
2.2 Guidance Revision 4 to Regulatory Guide (RG) 1.101 (Reference No. 7), issued in July 2003, endorses the guidance contained in Reference No. 5 as acceptable to the NRC staff as an alternative method to that described in the following guidance for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4):
Appendix 1 to NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980), and Nuclear Utilities Management Council (NUMARC) document, entitled NESP-007, Methodology for Development of Emergency Action Levels (Revision 2, January 1992).
Reference No. 6 provides guidance for developing or changing a standard emergency classification and action level scheme. In addition, this provided recommendations to assist licensees, consistent with Section IV.B to Appendix E of Part 50, in determining whether to seek prior NRC staff approval of deviations from the new guidance.
3.0 TECHNICAL EVALUATION
Since the proposed revision to the Exelon/AmerGen EALs were evaluated by Exelon/AmerGen to be an alternate method for complying with the regulations, the proposed changes were submitted to the NRC for approval prior to implementation by the licensees.
The licensees currently utilize an EAL scheme based on Reference No. 4. The licensees are converting to an EAL scheme based on Reference No 5 in accordance with the guidance from Reference No. 6.
The NRC staff has reviewed the application (Reference No. 1), responses to NRC RAIs (Reference No. 2), and the Oyster Creek response (Reference No. 3). The NRC staff reviewed the proposed EALs against the guidance in Reference No. 5 to determine if the EALs, as proposed, meet the following guidelines:
(1) Consistency, (i.e., the EALs would lead to similar decisions under similar circumstances at different plants);
(2) Human engineering and user friendliness; (3) Potential for classification upgrade only when there is an increasing threat to public health and safety; (4) Ease of upgrading and downgrading; (5) Thoroughness in addressing, and disposing of, the issues of completeness and accuracy raised regarding NUREG-0654 Appendix 1; (6) Technical completeness for each classification level; (7) A logical progression in classification for multiple events; and (8) Objective, observable values.
The NRC staff reviewed the proposed EALs against EALs implemented at other plants of a similar design and has determined that the proposed EALs are consistent with EALs implemented at other plants, uses objective and observable values, and is consistent with the intent of Reference No. 5.
The NRC staff has determined that the proposed EALs are worded such that human engineering and user friendliness concerns are addressed.
The NRC staff reviewed the proposed EAL sets, (a group of EALs within a category related to a common concern, i.e., the Unusual Event, Alert, Site Area Emergency, and General Emergency related to a failure of the plant to shutdown via an automatic scram would be considered an EAL set), and has determined that classification upgrades are based upon an increasing threat to public health and safety, can effectively support upgrading and downgrading, follows a logical progression for multiple events, and is in accordance with the intent of Reference No. 5.
The NRC staff reviewed the proposed EALs for technical completeness and accuracy and has determined that the proposed EALs are consistent with Reference No. 5, which was determined to be an acceptable alternative to NUREG-0654, Appendix 1 EALs (Reference No. 7).
4.0 CONCLUSION
The NRC staff performed a review of the proposed changes to the Exelon/AmerGen EALs described in Reference No. 1, as supplemented by Reference Nos. 2 and 3, and determined them to be consistent with the guidance of Reference No. 5. As such, the proposed EAL changes meet the requirements of 10 CFR 50.47(b) and Section IV.B of Appendix E to 10 CFR Part 50. The following are therefore acceptable:
Braidwood: Enclosure 1D to Reference No. 2, Attachment No. 1, including the deletion of EAL CU5 (from Reference No. 5). (ADAMS Accession No. ML063430106).
Byron: Enclosure 2D to Reference No. 2, Attachment No. 2, including the deletion of EAL CU5 (from Reference No. 5). (ADAMS Accession No. ML063460109).
Clinton: Enclosure 3D to Reference No. 2, Attachment No. 3, including the deletion of EAL CU5 (from Reference No. 5) and the deletion of the following Fission Product Barrier EALs from the current EAL scheme based upon Reference No. 4, (ADAMS Accession No. ML063460112):
Loss of Fuel Clad 2.d, Steamline Radiation, Potential Loss of Containment 1.f, Drywell Temperature, Loss of Reactor Coolant System (RCS) 3.e, Primary System Relief Valves.
Dresden: Enclosure 4D to Reference No. 2, Attachment No. 4, including the deletion of EAL CU5 (from Reference No. 5) and the deletion of the following Fission Product Barrier EALs from the current EAL scheme based upon Reference No. 4, (ADAMS Accession No. ML063460114):
Loss of Fuel Clad 2.d, Steamline Radiation, Potential Loss of Containment 1.f, Drywell Temperature, Loss of RCS 3.e, Primary System Relief Valves.
LaSalle: Enclosure 5D to Reference No. 2, Attachment No. 5, including the deletion of EAL CU5 (from Reference No. 5) and the deletion of the following Fission Product Barrier EALs from the current EAL scheme based upon Reference No. 4, (ADAMS Accession No. ML063460116):
Loss of Fuel Clad 2.d, Steamline Radiation, Potential Loss of Containment 1.f, Drywell Temperature, Loss of RCS 3.e, Primary System Relief Valves.
Limerick: Enclosure 6D to Reference No. 2, Attachment No. 6, including the deletion of EAL CU5 (from Reference No. 5), the deletion of EAL MA8 from the current EAL scheme based upon Reference No. 4, and the deletion of the following Fission Product Barrier EALs from the current EAL scheme based upon Reference No. 4, (ADAMS Accession No. ML063460119):
Loss of RCS 2.d.2, Stuck Open Safety Relief Valve, Potential Loss of RCS, Reactor Pressure Level cannot be determined.
Oyster Creek: Enclosure 7D to Reference No. 3, Attachment No. 7, including the deletion of EAL CU5 (from Reference No. 5). (ADAMS Accession No. ML063540086).
Peach Bottom: Enclosure 8D to Reference No. 2, Attachment No. 8, including the deletion of EAL CU5 (from Reference No. 5), the deletion of EAL MA8 from the current EAL scheme based upon Reference No. 4, and the deletion of the following Fission Product Barrier EALs from the current EAL scheme based upon Reference No. 4, (ADAMS Accession No. ML063460125):
Loss of RCS 2.d.2, Stuck Open Safety Relief Valve, Potential Loss of RCS, Reactor Pressure Level cannot be determined.
Quad Cities: Enclosure 9D to Reference No. 2, Attachment No. 9, including the deletion of EAL CU5 (from Reference No. 5) and the deletion of the following Fission Product Barrier EALs from the current EAL scheme based upon Reference No. 4, (ADAMS Accession No. ML063460127):
Loss of Fuel Clad 2.d, Steamline Radiation, Potential Loss of Containment 1.f, Drywell Temperature, Loss of RCS 3.e, Primary System Relief Valves.
5.0 REFERENCES
1.
Letter Number RS-06-114 from Exelon/AmerGen to the NRC dated August 15, 2006, Exelon/AmerGen Implementation of Emergency Action Levels Developed from NEI 99-01. ADAMS Accession No. ML062790096.
2.
Letter Number RS-06-170 from Exelon/AmerGen to the NRC dated December 1, 2006, Exelon/AmerGen Response to Request for Additional Information for Implementation of Emergency Action Levels Developed from NEI 99-01. ADAMS Accession No. ML063450456.
3.
Letter Number 2130-06-20439 from Exelon/AmerGen to the NRC dated December 14, 2006, Exelon/AmerGen Supplement to Submittal to Revise Oyster Creek Emergency Action Levels Developed from NEI 99-01. ADAMS Accession No. ML063540086.
4.
Nuclear Utilities Management Council (NUMARC) document, entitled NESP-007, Methodology for Development of Emergency Action Levels (Revision 2, January 1992). ADAMS Accession No. ML041120174.
5.
NEI 99-01 Methodology for Development of Emergency Action Levels (Revision 4, January 2003). ADAMS Accession No. ML041470143.
6.
Regulatory Issue Summary 2003-18, with Supplements 1 and 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels. ADAMS Accession Nos.
ML032580518, ML041550395, and ML051450482.
7.
Regulatory Guide 1.101, Revision 4, Emergency Planning and Preparedness for Nuclear Power Reactors. ADAMS Accession No. ML032020276.
8.
December 14, 2006, email informing NRC Staff of Exelon/AmerGens decision to supplement the submittal for TMI at a later date. ADAMS Accession No. ML070120274 Principal Contributor: D. Johnson, NSIR Date: January 17, 2007