RS-15-082, Response to Request for Additional Information License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors
Text
ArExelon Generation, 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.corn 10 CFR 50.90 10 CFR 50, Appendix E 10 CFR 50.4 RS- 15-082 RA-15-019 TMI-15-034 March 2, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, 50-457, and 72-73 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. 50-454, 50-455, and 72-68 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 1, 2 and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237, 50-249, and 72-37 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374, 72-70 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353, and 72-65 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Peach Bottom Atomic Power Station, Units 1, 2 and 3 Facility Operating License DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278 and 72-29
U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes March 2, 2015 Page 2 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254, 50-265, and 72-53 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only No. DPR-73 NRC Docket No. 50-320
Subject:
Response to Request for Additional Information License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, "Developmentof Emergency Action Levels for Non-Passive Reactors"
References:
- 1) Letter from James Barstow (Exelon Generation Company, LLC) to U.S.
Nuclear Regulatory Commission - License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors,"
dated May 30, 2014 (ML14164A054)
- 2) U.S. Nuclear Regulatory Commission Electronic Mail Preliminary Request for Information Regarding Emergency Action Level Fleet Amendments, dated November 11, 2014 By letter dated May 30, 2014 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a license amendment request to support changes to the Emergency Plans for the facilities listed above. Specifically, the proposed changes involve revising the Emergency Plans for the affected facilities to adopt the Nuclear Energy Institute's (NEI's) revised Emergency Action Level (EAL) schemes described in NEI 99-01, Revision 6, "Developmentof Emergency Action Levels for Non-Passive Reactors," which have been endorsed by the NRC as documented in an NRC letter dated March 28, 2013.
10 CFR 50, Appendix E, Section IV.B.2 stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Exelon's currently approved Emergency Plan EAL schemes are based on the guidance established in NEI 99-01, Revision 5, "Methodologyfor Development of Emergency Action Levels." Exelon is proposing to adopt the EAL schemes based on the latest NRC-endorsed guidance, which are described in NEI 99-01, Revision 6.
U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes March 2, 2015 Page 3 Subsequently, in an electronic mail request dated November 11, 2014 (Reference 2), the NRC indicated that it had reviewed the information submitted in the Reference 1 letter. The NRC identified a number of preliminary questions concerning the proposed EAL changes and requested additional clarifying information to support its continued review. The preliminary questions in Reference 2 were further discussed during teleconferences on December 2, 2014, and January 8, 2015, between Exelon and NRC representatives.
Accordingly, Attachment 1 provides Exelon's response to the request for information contained in the Reference 2 electronic mail message. Attachment 1 also includes additional information requesting minor clarifying changes to other EALs as a result of the discussions with the NRC.
Attachments 2 through 12 include revised red-line markups along with revised clean pages of the affected EALs and supporting Basis information for each of the plants.
Exelon has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in the Reference 1 letter. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal 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 amendment.
There are no regulatory commitments contained in this submittal.
If you have any questions concerning 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 2nd day of March 2015.
Respectfully, James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:
Attachment 1 - Response to the Request for Additional Information - License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, "Developmentof Emergency Action Levels for Non-Passive Reactors"
U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes March 2, 2015 Page 4 - Revised Radiological Emergency Plan Annex Information for Braidwood Station
- Enclosure 2A - EAL Comparison Matrix Document
- Enclosure 2B - EAL Red-Line Basis Document
- Enclosure 2C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Byron Station
- Enclosure 3A - EAL Comparison Matrix Document
- Enclosure 3B - EAL Red-Line Basis Document
" Enclosure 3C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Clinton Power Station
- Enclosure 4A - EAL Comparison Matrix Document
- Enclosure 4B - EAL Red-Line Basis Document
- Enclosure 4C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Dresden Station
" Enclosure 5A - EAL Comparison Matrix Document
- Enclosure 5B - EAL Red-Line Basis Document
- Enclosure 5C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for LaSalle County Station
- Enclosure 6A - EAL Comparison Matrix Document
- Enclosure 6B - EAL Red-Line Basis Document
" Enclosure 6C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Limerick Generating Station
- Enclosure 7A - EAL Comparison Matrix Document
- Enclosure 7B - EAL Red-Line Basis Document
- Enclosure 7C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Oyster Creek Nuclear Generating Station
- Enclosure 8A - EAL Comparison Matrix Document
- Enclosure 8B - EAL Red-Line Basis Document
- Enclosure 8C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Peach Bottom Atomic Power Station
- Enclosure 9A - EAL Comparison Matrix Document
- Enclosure 9B - EAL Red-Line Basis Document
- Enclosure 9C - EAL Basis Document
U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes March 2, 2015 Page 5 0 - Revised Radiological Emergency Plan Annex Information for Quad Cities Nuclear Station
- Enclosure 10A - EAL Comparison Matrix Document
- Enclosure 10B - EAL Red-Line Basis Document
- Enclosure 10C - EAL Basis Document 1 - Revised Radiological Emergency Plan Annex Information for Three Mile Island Station
- Enclosure 11A - EAL Comparison Matrix Document
- Enclosure 11 B - EAL Red-Line Basis Document
- Enclosure 11C - EAL Basis Document cc: w/o Attachments (CD copy)
Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood NRC Senior Resident Inspector - Byron NRC Senior Resident Inspector - Clinton NRC Senior Resident Inspector - Dresden NRC Senior Resident Inspector - LaSalle NRC Senior Resident Inspector - Limerick NRC Senior Resident Inspector - Oyster Creek NRC Senior Resident Inspector - Peach Bottom NRC Senior Resident Inspector - Quad Cities NRC Senior Resident Inspector - Three Mile Island NRC Project Manager, NRR - Exelon Fleet NRC Project Manager, NRR - Braidwood NRC Project Manager, NRR - Byron NRC Project Manager, NRR - Clinton NRC Project Manager, NRR - Dresden NRC Project Manager, NRR - LaSalle NRC Project Manager, NRR - Limerick NRC Project Manager, NRR - Oyster Creek NRC Project Manager, NRR - Peach Bottom NRC Project Manager, NRR - Quad Cities NRC Project Manager, NRR - Three Mile Island R. R. Janati, Commonwealth of Pennsylvania S. Gray, State of Maryland Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Illinois Emergency Management Agency Division of Nuclear Safety
Text
ArExelon Generation, 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.corn 10 CFR 50.90 10 CFR 50, Appendix E 10 CFR 50.4 RS- 15-082 RA-15-019 TMI-15-034 March 2, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, 50-457, and 72-73 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. 50-454, 50-455, and 72-68 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 1, 2 and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237, 50-249, and 72-37 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374, 72-70 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353, and 72-65 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Peach Bottom Atomic Power Station, Units 1, 2 and 3 Facility Operating License DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278 and 72-29
U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes March 2, 2015 Page 2 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254, 50-265, and 72-53 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only No. DPR-73 NRC Docket No. 50-320
Subject:
Response to Request for Additional Information License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, "Developmentof Emergency Action Levels for Non-Passive Reactors"
References:
- 1) Letter from James Barstow (Exelon Generation Company, LLC) to U.S.
Nuclear Regulatory Commission - License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors,"
dated May 30, 2014 (ML14164A054)
- 2) U.S. Nuclear Regulatory Commission Electronic Mail Preliminary Request for Information Regarding Emergency Action Level Fleet Amendments, dated November 11, 2014 By letter dated May 30, 2014 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a license amendment request to support changes to the Emergency Plans for the facilities listed above. Specifically, the proposed changes involve revising the Emergency Plans for the affected facilities to adopt the Nuclear Energy Institute's (NEI's) revised Emergency Action Level (EAL) schemes described in NEI 99-01, Revision 6, "Developmentof Emergency Action Levels for Non-Passive Reactors," which have been endorsed by the NRC as documented in an NRC letter dated March 28, 2013.
10 CFR 50, Appendix E, Section IV.B.2 stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Exelon's currently approved Emergency Plan EAL schemes are based on the guidance established in NEI 99-01, Revision 5, "Methodologyfor Development of Emergency Action Levels." Exelon is proposing to adopt the EAL schemes based on the latest NRC-endorsed guidance, which are described in NEI 99-01, Revision 6.
U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes March 2, 2015 Page 3 Subsequently, in an electronic mail request dated November 11, 2014 (Reference 2), the NRC indicated that it had reviewed the information submitted in the Reference 1 letter. The NRC identified a number of preliminary questions concerning the proposed EAL changes and requested additional clarifying information to support its continued review. The preliminary questions in Reference 2 were further discussed during teleconferences on December 2, 2014, and January 8, 2015, between Exelon and NRC representatives.
Accordingly, Attachment 1 provides Exelon's response to the request for information contained in the Reference 2 electronic mail message. Attachment 1 also includes additional information requesting minor clarifying changes to other EALs as a result of the discussions with the NRC.
Attachments 2 through 12 include revised red-line markups along with revised clean pages of the affected EALs and supporting Basis information for each of the plants.
Exelon has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in the Reference 1 letter. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal 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 amendment.
There are no regulatory commitments contained in this submittal.
If you have any questions concerning 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 2nd day of March 2015.
Respectfully, James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:
Attachment 1 - Response to the Request for Additional Information - License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, "Developmentof Emergency Action Levels for Non-Passive Reactors"
U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes March 2, 2015 Page 4 - Revised Radiological Emergency Plan Annex Information for Braidwood Station
- Enclosure 2A - EAL Comparison Matrix Document
- Enclosure 2B - EAL Red-Line Basis Document
- Enclosure 2C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Byron Station
- Enclosure 3A - EAL Comparison Matrix Document
- Enclosure 3B - EAL Red-Line Basis Document
" Enclosure 3C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Clinton Power Station
- Enclosure 4A - EAL Comparison Matrix Document
- Enclosure 4B - EAL Red-Line Basis Document
- Enclosure 4C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Dresden Station
" Enclosure 5A - EAL Comparison Matrix Document
- Enclosure 5B - EAL Red-Line Basis Document
- Enclosure 5C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for LaSalle County Station
- Enclosure 6A - EAL Comparison Matrix Document
- Enclosure 6B - EAL Red-Line Basis Document
" Enclosure 6C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Limerick Generating Station
- Enclosure 7A - EAL Comparison Matrix Document
- Enclosure 7B - EAL Red-Line Basis Document
- Enclosure 7C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Oyster Creek Nuclear Generating Station
- Enclosure 8A - EAL Comparison Matrix Document
- Enclosure 8B - EAL Red-Line Basis Document
- Enclosure 8C - EAL Basis Document - Revised Radiological Emergency Plan Annex Information for Peach Bottom Atomic Power Station
- Enclosure 9A - EAL Comparison Matrix Document
- Enclosure 9B - EAL Red-Line Basis Document
- Enclosure 9C - EAL Basis Document
U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes March 2, 2015 Page 5 0 - Revised Radiological Emergency Plan Annex Information for Quad Cities Nuclear Station
- Enclosure 10A - EAL Comparison Matrix Document
- Enclosure 10B - EAL Red-Line Basis Document
- Enclosure 10C - EAL Basis Document 1 - Revised Radiological Emergency Plan Annex Information for Three Mile Island Station
- Enclosure 11A - EAL Comparison Matrix Document
- Enclosure 11 B - EAL Red-Line Basis Document
- Enclosure 11C - EAL Basis Document cc: w/o Attachments (CD copy)
Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood NRC Senior Resident Inspector - Byron NRC Senior Resident Inspector - Clinton NRC Senior Resident Inspector - Dresden NRC Senior Resident Inspector - LaSalle NRC Senior Resident Inspector - Limerick NRC Senior Resident Inspector - Oyster Creek NRC Senior Resident Inspector - Peach Bottom NRC Senior Resident Inspector - Quad Cities NRC Senior Resident Inspector - Three Mile Island NRC Project Manager, NRR - Exelon Fleet NRC Project Manager, NRR - Braidwood NRC Project Manager, NRR - Byron NRC Project Manager, NRR - Clinton NRC Project Manager, NRR - Dresden NRC Project Manager, NRR - LaSalle NRC Project Manager, NRR - Limerick NRC Project Manager, NRR - Oyster Creek NRC Project Manager, NRR - Peach Bottom NRC Project Manager, NRR - Quad Cities NRC Project Manager, NRR - Three Mile Island R. R. Janati, Commonwealth of Pennsylvania S. Gray, State of Maryland Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Illinois Emergency Management Agency Division of Nuclear Safety