ML18037A786

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

ML18037A786
Person / Time
Site:	FitzPatrick
Issue date:	01/31/2018
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML18037A782	List: JAFP-18-0014, Attachment 1: 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 JAFP-18-0014, Enclosure 2A- EAL Comparison Matrix Document JAFP-18-0014, Enclosure 2C- EAL Basis Document JAFP-18-0014, James A. FitzPatrick Nuclear Power Plant - 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 ML18037A786 ML18037A787 ML18037A788 ML18037A790 ML18037A792 ML18037A793 ML18037A795
References
JAFP-18-0014
Download: ML18037A786 (3)

Text

,i LS' £ s:.,..* Exelon Generation JAFP-18-0014 January 31, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 James A. FitzPatrick Nuclear Power Plant

• Renewed Facility Operating License No. DPR-59 Docket No. 50-333 James A. FitzPatrick Nuclear Power Plant Independent Spent Fuel Storage Installation General License SFGL-12 Docket No.72-012 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 10 CFR 50, Appendix E 10 CFR 50.4

Subject:

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"

References:

1) Letter from Mark Thaggard (U.S. Nuclear Regulatory Commission) to Susan Perkins-Grew (Nuclear Energy Institute)

-U.S. Nuclear Regulatory Commission Review and Endorsement of NE/ 99-01, Revision 6, November 2012, dated March 28, 2013 2) NRG Regulatory Issue Summary (RIS) 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated August 19, 2011 In accordance with 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to the licenses cited for the James A. FitzPatrick Nuclear Power Plant (FitzPatrick).

Specifically, the proposed changes involve revising the Emergency Plan related to the cited facilities to adopt the Nuclear Energy lnstitute's (NEl's) revised Emergency Action Level (EAL) schemes described in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors,"which have been endorsed by the NRG as documented in an NRG letter dated March 28, 2013 (Reference 1 ). A-'I-4-~ ji//v/55 ;J~f< ;J/vfSS U.S. Nuclear Regulatory Commission License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes Docket Nos. 50-333 and 72-012 January 31, 2018 Page2 1 O 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. Regulatory Issue Summary 2005-02, Revision 1 (Reference 2} also indicates that a revision to an entire EAL scheme, from NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, "to another NRG-endorsed EAL scheme, must be submitted for prior NRC approval as specified in Section IV.B of Appendix E to 10 CFR 50. Therefore, pursuant to 1 O CFR 50.90, Exelon hereby requests NRC review and approval of revisions to Emergency Plan EALs supporting FitzPatrick.

Currently, FitzPatrick's approved Emergency Plan EAL schemes are based on the guidance established in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels." Exelon is proposing to adopt the EAL schemes based on the latest NRG-endorsed guidance, which are described in NEI 99-01, Revision 6. Attachment 1 provides an evaluation of the proposed changes. Attachment 2 provides additional supporting information related to changes for the FitzPatrick Emergency Plan. The information contained in Attachment 2 includes the following:

• * * *

• EAL Comparison Matrix Document EAL Red-Line Basis Document EAL Basis Document EAL Front Matter EAL Procedure Matrix The proposed changes have been reviewed by the Plant Operations Review Committee (PORC) in accordance with the requirements of the FitzPatrick Quality Assurance Program. Exelon requests approval of the proposed changes by January 31, 2019, and requests that the changes be implemented on or before December 31, 2019. The requested implementation period,is needed in order to facilitate and coordinate the necessary training with established training cycles for the Operations' crews as well as other Emergency Response Organization (ERO) personnel and allows time to complete the training around outage schedules.

There are no regulatory commitments contained in this submittal.

Pursuant to 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the State of New York of this application for license amendments by transmitting a copy of this letter and its supporting attachments to the designated state officials.

U.S. Nuclear Regulatory Commission License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes Docket Nos. 50-333 and 72-012 January 31, 2018 Page3 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 31st day of January 2018. David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

Attachment 1 -Evaluation of Proposed Changes Attachment 2 -Discussion of Revision to the Radiological Emergency Plan for James A. FitzPatrick Nuclear Power Plant (CD Copy)

• Enclosure 2A -EAL Comparison Matrix Document

• Enclosure 28 -EAL Red-Line Basis Document

• Enclosure 2C -EAL Basis Document

• Enclosure 20 -EAL Front Matter

• Enclosure 2E -EAL Procedure Matrix cc: w/ Attachments (CD copy -Attachment

2) Regional Administrator-NRC Region I NRC Senior Resident Inspector-James A. FitzPatrick Nuclear Power Plant NRC Project Manager, NRR-James A. FitzPatrick Nuclear Power Plant A. L. Peterson, NYSERDA