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Transmittal of Exelon Nuclear Radiological Emergency Plan Revision 1 to EP-AA-1005, Addendum 3, Emergency Action Levels
	ML16042A632
Person / Time
Site:	LaSalle
Issue date:	02/11/2016
From:	Imburgia D; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML16042A631	List: ML16042A632; RS-16-047, EP-AA-1005, Addendum 3, Revision 1, Emergency Action Levels for LaSalle Station; RS-16-047, LaSalle County, Units 1 and 2 - Transmittal of Exelon Nuclear Radiological Emergency Plan Revision 1 to EP-AA-1005, Addendum 3, Emergency Action Levels.;
References
	RS-16-047
	Download: ML16042A632 (11)
	v • d • e

Exelon Confidential/Proprietary Information - Withhold Under 10 CFR 2.390 contains Exelon Confidential/Proprietary Information; upon separation this cover letter and Attachments 1 and 2 are decontrolled.

RS-16-047 February 11, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374, and 72-70 Exelon Nuclear Radiological Emergency Plan Revision 10 CFR 50.54(q)(5) 10 CFR 50.4 10 CFR 72.44(f)

In accordance with 10 CFR 50.4(b)(5),

11Emergency Plan and related submissions," Exelon Generation Company, LLC (EGC) is submitting an Emergency Plan Addendum revision for LaSalle County Station (LaSalle) as listed in the table below.

Document I

Title I

EP-AA-1005, Addendum 3 1

I Emergency Action Levels for LaSalle Station -

I Exelon Confidential/Proprietary The change to the Emergency Plan Addendum was evaluated under the requirements of 10 CFR 50.54(q) and was determined not to result in a reduction in the effectiveness of the Emergency Plan for LaSalle. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50.4(b)(5). The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. of this letter is proprietary and confidential and contains trade secrets and commercial or financial information. EGC maintains this information on a confidential basis and protects it from disclosure to the general public or unauthorized individuals. EGC requests that the Emergency Plan Addendum contained in Attachment 3 be withheld from public disclosure pursuant to 1 O CFR 2.390(a)(4), and has attached an affidavit for this purpose (Attachment 2).

However, if the NRC intends to place any of this information in the Public Document Room or on the Agencywide Documents Access and Management System or produce it in response to a Freedom of Information Act (FOIA) request, EGC requests the opportunity to redact the materials consistent with established FOIA exemptions and precedent.

In addition, as required by 10 CFR 50.54(q)(5), this submittal includes a summary analysis of the changes to the Emergency Plan Addendum (Attachment 1 ).

Exelon Confidential/Proprietary Information - Withhold Under 10 CFR 2.390 contains Exelon Confidential/Proprietary Information; upon separation this cover letter and Attachments 1 and 2 are decontrolled.

U.S. Nuclear Regulatory Commission Emergency Plan Addendum Revision February 11, 2016 Page2 This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

A copy of the revised Emergency Plan Addendum and supporting change summary analysis are included in the attachments to this letter.

There are no regulatory commitments in this submittal.

If you have any questions or require additional information, please contact Richard Gropp at (610) 765-5557.

Respectfully, "Dominic M. Imburgia Manager, Licensing Programs Exelon Generation Company, LLC Attachments:

1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis

2. Affidavit

3. EP-AA-1005, Addendum 3, Revision 1, "Emergency Action Levels for LaSalle Station Exelon Confidential/Proprietary" cc:

Regional Administrator - NRC Region Ill Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRC Senior Resident Inspector - LaSalle County Station NRC Project Manager, NRR - LaSalle County Station

ATTACHMENT 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1 of 4 Procedure title 1 O CFR 50.54(g)(5) Procedure Change Summary Analysis Exelon Generation Company, LLC (EGC) is submitting the following Emergency Plan Addendum revision for LaSalle County Station (LaSalle):

EP-AA-1005, Addendum 3, Revision 1, 11Emergency Action Levels for LaSalle Station 11 This document contains Exelon Confidential/Proprietary Information and is requested to be withheld from public disclosure pursuant to 1 O CFR 2.390.

Description of procedure EP-AA-1005, Addendum 3 describes the Emergency Action Levels (EALs) implemented at LaSalle County Station.

Description of change This revision to EP-AA-1005, Addendum 3 for LaSalle incorporates the following changes:

1. Implementation of NEI 99-01, Revision 6, 11Development of Emergency Action Levels for Non-Passive Reactors, 11 which involved a complete rewrite/formatting of the document.

2. Establishes EAL thresholds for the NRC pre-approved EALs RG2 and RS2 and an additional threshold for RA2 based on Spent Fuel Pool (SFP) levels.

3. Revised EAL Thresholds for RG1.1, RS1.1, RA 1.1, and RU1.2 based on changes being made to the LaSalle Offsite Dose Calculation Manual (ODCM).

A more detailed description of the changes is provided below.

1. The revised EAL schemes based on NEI 99-01, Revision 6 were submitted to the NRC in a License Amendment Request (LAR) dated May 30, 2014. The NRC approved the LAR as documented in a letter and supporting Safety Evaluation Report (SER) dated July 28, 2015. Training was satisfactorily completed for the PBAPS and supporting Corporate Emergency Response Organization (ERO) personnel on the revised EAL schemes during the fourth quarter of 2015. As a result, the NRG-approved EAL schemes based on the NEI 99-01, Revision 6 guidance were implemented and this revision to EP-AA-1005, Addendum 3 reflects the changes.

2. As part of the NRC approval of the new EAL schemes, three (3) new thresholds were approved generically without specific threshold level values for the SFP being included.

The levels are based on enhanced SFP level devices placed in service in accordance with the information provided in Section 1.4, of NRC Order EA-12-051. NEI 99-01, Revision 6 recommended that these EAL thresholds be implemented when the enhanced SFP level instrumentation is available for use. At LaSalle, the enhanced SFP level instruments were placed in service in accordance with a site-approved design change package. For the new EALs RG2 and RS2 a 11site specific level 3 11 threshold value is used and for RA2 there is a third threshold that uses a site specific level 2" value. Based on the site-approved design change package the following thresholds were used for each of the site-specific values:

Page 2 of 4 Based on site-approved design change documentation the "site specific level 3 value" was selected to be 820.42' as follows.

The LaSalle design change documentation establishes at 820 1-0 11 as the "spent fuel pool level where fuel remains covered and actions to implement make-up water addition should no longer be deferred." However, the design change documentation notes that the instrumentation has a dead band of 5 11 above level 3, which cannot read. Therefore, the lowest reliable indicated level would correspond to approximately 820'-5". The instruments read out in feet to the 1/100th of a foot (i.e., reads in feet and not a combination of feet plus inches), so 820' -5" would correspond to 820.42'.

The SFP level calibration range was taken into consideration in establishing the threshold.

o Unit 1:

Per instrument calibration procedures, the Unit 1 SFP indication lowest displayed level is 820.35' to 820.39' at 4ma DC.

o Unit Per instrument calibration procedures, the Unit 2 SFP indication lowest readable level is 820.25' to 820.29' at 4ma DC.

In consideration of the instrument capabilities and the calibration range, a threshold value of 820.42' is selected to be used in EALs RG2 and RS2, since it is on scale and readable on both units instruments. This value also takes into account the 5" dead band specified in design change documentation and is indicative of the immediate need to restore fuel pool level.

The 11site specific level 2 11 value is 830.00' as indicated on the applicable level instrumentation. This value includes the site-specific constraints and limitations specific to LaSalle in accordance with approved design change documentation.

This level is considered the SFP level that is adequate to provide substantial radiation shielding for a person standing on the SFP operating deck.

3. Along with implementation of NEI 99-01, Revision 6 of the EALs, the LaSalle ODCM is being revised to incorporate minor changes throughout including the following changes to equations which are used in the thresholds calculation for RG 1.1, RS 1.1, RA 1.1 and RU1.2.

The minor errors corrected in the ODCM included revising references 11 to and 11 "to

in equations. The two (2) errors occurred when developing Revision 0 of the ODCM in August 2005 from Revision 8 (that includes Revision 7 of Chapter 10 dated September 2003) of the LaSalle Emergency Plan Annex.

Also, a 11s; 11 symbol was corrected to 11<

11 symbol. This error occurred when creating Revision 1.9 of the LaSalle Emergency Plan Annex (Chapter 10) in March 1998 from Revision 1.8 (November 1996).

The changes to the ODCM equations resulted in a slight change in the calculated threshold value and the resulting change is described in the table below. All values are in µCi/sec.

EP-EAL-0605 GE SAE Alert UE Revision 1 8.02E+09 8.02E+08 9.15E+07

9.15E+05 Revision 2 8.26E+09 8.26E+08 8.26E+07 9.42E+05 Page 3 of 4 This is the current calculated value, the implementation of NEI 99-01, Revision 6 approved EALs would have changed this value to 8.02E+07 µCi/sec, but based on the ODCM changes, the Revision 6 value has to be revised to 8.26E+07 µCi/sec as shown in the documentation for choosing radiological gaseous effluent EAL threshold values at LaSalle.

Description of how the change still complies with regulations This revision to the EP-AA-1005, Addendum 3 continues to satisfy the applicable Emergency Planning requirements established in 1 O CFR 50.47(b)(4) and the Program Element guidance specified in NUREG-0654, Section 11.D as noted below.

1. This revision to EP-AA-1005, Addendum 3 implements the EAL scheme changes reviewed and approved by the NRC as documented in its letter dated July 28, 2015. As such, the NRC has determined that this revision to the Emergency Plan Addendum is acceptable and the changes satisfy regulatory requirements and commitments.

2. Updating the threshold values for EALs RG2, RS2, and RA2 based on a site-approved design change package does not alter the meaning or intent of the basis for the approved EALs. The applicable emergency planning regulations and commitments continue to be met.

3. Updating the threshold values for RG 1.1, RS 1.1, RA 1.1 based on an approved change to the technical basis change does not alter the meaning or intent of the basis of the approved EALs. The applicable emergency planning regulations and commitments continue to be met.

Description of why the change is not a Reduction in Effectiveness (RIE)

1. The change to the LaSalle EAL schemes reflects the NRC's approval of the LAR as documented in its letter and supporting SER dated July 28, 2015 (i.e., LaSalle Amendment No. 215 to Facility Operating License No. NPF-11 and Amendment No. 201 to Facility Operating License No. NPF-18).

The applicable emergency planning regulations and commitments continue to be met.

Therefore, this change does not result in a reduction in effectiveness of the LaSalle Emergency Plan.

2. The changes to the EAL schemes RG2, RS2, and RA2 reflect the changes as approved by the NRC as documented in its letter and supporting SER dated July 28, 2015. The approved EALs had indicated that a site-specific threshold value would be added upon installation of enhanced SFP level devices in accordance with NRC Order EA-12-051.

LaSalle has subsequently installed the enhanced SFP level devices and threshold values have been established in accordance with a site-approved design change evaluation.

For EALs RG2 and RS2 the value of 820.42' as indicated on applicable level instrumentation was chosen as being indicative of the immediate need to restore fuel pool level. For EAL RA2.3 the value of 830.00 1 as indicated on applicable level instrumentation was chosen as being the SFP level that is adequate to provide substantial radiation shielding for a person standing on the SFP operating deck.

Page 4 of 4 The site-specific levels were determined in accordance with N RC Order EA-12-051 and NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," and applicable Owner's Group guidance, and have been modified to reflect site-specific constraints and limitations associated with the design and operation of instrumentation as required by the developer guidance in the NRG-endorsed NEI 99-01, Revision 6 guidance.

Updating the EAL threshold values based on an approved technical analysis does not alter the meaning or intent of the basis of the approved EALs. The applicable emergency planning regulations and commitments continue to be met. Therefore, this change does not result in a reduction in effectiveness of the LaSalle Emergency Plan.

3. The change to the EAL schemes reflects the revision made to the LaSalle ODCM that incorporate minor changes throughout, including changes to equations which are used in the thresholds calculation for thresholds RG 1.1, RS 1.1, RA 1.1 and RU 1.2. NEI 99-01, Revision 6 allows for the use of the ODCM methodology to determine the calculated thresholds for these EALs. Since the equations used in this methodology changed, it required a revision to the threshold technical basis criteria for choosing radiological gaseous effluent EAL threshold values for LaSalle.

Updating the EAL threshold values based on an approved technical basis change does not alter the meaning or intent of the basis of the approved EAL. The applicable emergency planning regulations and commitments continue to be met. Therefore, this change does not result in a reduction in effectiveness of the LaSalle Emergency Plan.

ATTACHMENT 2 Radiological Emergency Plan Addendum Revision Affidavit Page 1 of 3 AFFIDAVIT OF DOMINIC M. IMBURGIA DOCKET NOS. 50-373, 50-374, and 72-70 I, Dominic M. Imburgia, Manager, Licensing Programs, Exelon Generation Company, LLC, do hereby affirm and state:

1. I am Manager, Licensing Programs for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf of EGC.

2. I am further authorized to review the documents sought to be withheld from public disclosure in connection with submittals to the Nuclear Regulatory Commission (

11NRC 11

):

EP-AA-1005, Addendum 3, Revision 1, 11Emergency Action Levels for LaSalle Station 11

3. I am also authorized to apply to the NRC for the withholding of the aforementioned documents from public disclosure under 1 O CFR 2.390(a)(4) and 9.17(a)(4) on the grounds that the documents contain privileged or confidential or proprietary commercial information. The documents EGC seeks to withhold from public disclosure have been marked "Proprietary" and are summarized in the attachment to my Affidavit.

4. On behalf of EGC, I request that the documents marked by EGC as 11Proprietary 11 and described in the attached list (Appendix 1) be withheld, in their entirety, by the NRC from public disclosure.

5. In making this application for withholding of proprietary and confidential information of which EGC is the owner, EGC relies on 1 O CFR 2.390(a)(4) and 1 O CFR 9.17(a)(4).

The proprietary documents contain privileged or confidential or proprietary commercial information.

6. The proprietary information described in Appendix 1 should be withheld from disclosure by the NRC pursuant to the policy reflected in 10 CFR 2.390(a)(4), and for the following reasons to be considered pursuant to 1 O CFR 2.390(b)(4):

i.. The documents are each either a policy, procedure, process, technical requirements document, or other document that forms part of the Exelon Nuclear Management Model (

11 ENMM 11 ).

ii. The ENMM is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business. It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the ENMM.

EGC derives economic benefit from the ENMM in terms of increased efficiency and improved results as well as revenue generated from EGC's sale or licensing of the ENMM.

Page 2 of 3 iii. The documents are now, and have been, held in confidence by EGC. EGC does not customarily make these documents available to the public. EGC has not authorized making the documents available through public sources.

iv. EGC is providing the NRC with the documents and information in confidence.

v. Economic harm would come to EGC with the publication of the individual documents that form the ENMM, as it would reduce or eliminate the need for any third party to purchase or license the ENMM from EGC, and would reduce the competitive position of EGC based on the benefits that the ENMM provides to EGC in the management of its own nuclear plants. The ENMM is considered by EGC to be a very valuable part of our intellectual property and it would be very difficult, costly and time-consuming for another to duplicate it without access to these documents.

7. EGC requests that the document listed in Appendix 1 be withheld from public disclosure based on the reasons stated above in paragraph 6.i. through 6.v.

I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knowledge, information, and belief.

~~tia~

Manager, Licensing Programs Exelon Generation Company, LLC Date: February 11, 2016 Page 3 of 3 Appendix 1: Information that Should Be Withheld from Public Disclosure Date or Revision I**

- Descriptiorrof Document Revision 1 Entire document exempt from disclosure under 1 O CFR 2.390(a)(4) and EP-AA-1005, Addendum 3 I 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.