ML24206A125

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Revision of Three Procedures and Two Forms That Implement the Radiological Emergency Response Plan (RERP)
ML24206A125
Person / Time
Site: Wolf Creek, Peach Bottom  Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 07/24/2024
From: Hamman D
Wolf Creek
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
000564
Download: ML24206A125 (1)


Text

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831 Dustin T. Hamman Director Nuclear and Regulatory Affairs July 24, 2024 000564 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket Nos. 50-482 and 72-79: Revision of Three Procedures and Two Forms that Implement the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS)

Commissioners and Staff:

In accordance with 10 CFR 50.54(q)(5) and 10 CFR 72.44(f), WCGS is submitting a change to the emergency plan. Specifically, three procedures and two forms that implement the WCGS RERP have been revised. The revised documents are identified below:

Procedure Effective Date Form Effective Date AP 06-002, Rev. 024 June 26, 2024 EPF 06-001-03, Rev. 005 June 26, 2024 EPP 06-001, Rev. 032 June 26, 2024 EPF 06-001-04, Rev. 004 June 26, 2024 EPP 06-006, Rev. 011 June 26, 2024 The attached summary of the changes to the implementing procedures and forms explains that these changes do not reduce the effectiveness of the WCGS RERP.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4204.

Sincerely, Dustin T. Hamman DTH/jkt

Attachment:

Summary of Changes to Three Procedures and Two Forms that Implement the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS) cc:

S. S. Lee (NRC), w/a J. D. Monninger (NRC), w/a G. E. Werner (NRC), w/a Director of Division of Fuel Management (NRC), w/a Senior Emergency Preparedness Inspector (NRC), w/a Senior Resident Inspector (NRC), w/a WC Licensing Correspondence - RA 24-000564, w/a

Attachment to 000564 Page 1 of 3 Summary of Changes to Three Procedures and Two Forms that Implement the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS)

1. Procedure AP 06-002, RADIOLOGICAL EMERGENCY RESPONSE PLAN (RERP), Rev.

024 Procedure AP 06-002 has been revised. There were six areas of change for this revision.

Ready for Deployment Radiological monitoring teams have a goal of 60 minutes from the declaration of Alert or greater emergency to be ready for deployment to confirm effluent readings and verify plume emission and locations. During the 2023 NRC EP Exercise Evaluation exit meeting conducted December 20, 2023, the NRC noted that the procedure does not provide a clear definition of ready for deployment. A minor violation was issued with no cross-cutting aspects applied. The change is to add a definition for Ready for Deployment to the procedure.

Wolf Creek Joint Media Center The Wolf Creek Joint Media Center (JMC) is a public information facility with dedicated space that provides a central location for coordinated dissemination of timely and accurate information to the public and media. The proposed change is to update wording to better reflect the description of the Joint Media Center. The change also updates the terminology Clearinghouse to Center.

Lyon County Reception Center Coffey County and Lyon County have a mutual aid agreement to act as a host county to provide reception and care for evacuees from the effective 10-mile EPZ. The mutual aid agreement has been modified to change the reception center location from the Neosho Rapids Grade School, located in Neosho Rapids, KS, to the Hartford Jr./Sr. High School, located in Hartford, KS. The change describes the Lyon County Reception Center location and provides directions to the Hartford Jr./Sr. High School.

Evacuation Time Estimate (ETE)

The change provides updated evacuation time estimates for the 10-mile emergency planning zone (EPZ) based on the latest decennial census data. The updated ETE analysis is documented in to the Wolf Creek Generating Station Development of Evacuation Time Estimates Report KLD TR-1256 dated August 9, 2022.

Eliminating Pagers This change eliminates the use of pagers as a communication method for notifying key emergency response organization (ERO) personnel who are required to carry a pager during their duty period. The Automatic Dialing System will continue to call and text ERO responders on their mobile device(s). Mobile devices, such as smart phones, provide voice and text capability that provides the same capability as a pager. The associated infrastructure and mobile device improvements have evolved into a reliable replacement for pagers with equal or better coverage.

Administrative Numerous editorial / administrative changes are being made in this revision. The proposed changes include grammar and punctuation, step formats, organization / title changes, and minor wording changes. The changes provide consistency and alignment throughout the procedure and do not impact the content or functions described in the emergency plan. The

Attachment to 000564 Page 2 of 3 commitment step notations in the forms section are being updated to align the format used for commitment steps within the procedure. This provides consistency and aligns with AP 15C-001, PROCEDURE WRITERS GUIDE.

These changes do not reduce the effectiveness of the Wolf Creek Radiological Emergency Response Plan.

2. Procedure EPP 06-001, CONTROL ROOM OPERATIONS, Rev. 032 Procedure EPP 06-001 has been revised. The procedure provides guidance for the Shift Manager to determine the appropriate instructions for evacuating on-site personnel upon the declaration of an emergency classification.

Coffey County and Lyon County have a mutual aid agreement to function as a host county to provide reception and care for evacuees from the effective 10-mile EPZ. The mutual aid agreement has been modified to change the reception center location from the Neosho Rapids Grade School, located in Neosho Rapids, KS, to the Hartford Jr./Sr. High School, located in Hartford, KS.

The change updates the location for evacuation onsite personnel to the Lyon County Reception Center from Neosho Rapids, KS, to Hartford, KS.

This change does not reduce the effectiveness of the Wolf Creek Radiological Emergency Response Plan.

3. Procedure EPP 06-006, PROTECTIVE ACTION RECOMMENDATIONS, Rev. 011 Procedure EPP 06-006 has been revised. The procedure provides guidelines for Wolf Creek Generating Station to formulate and recommend protective action measures to the State of Kansas and Coffey County authorities.

The change updates the 10-mile evacuation population and times based on 2020 census data as documented in Wolf Creek Generating Station Development of Time Estimate August 2022. New notes were also added to the procedure that define the three fission product barriers as the Fuel Clad, Reactor Coolant System, and Containment and give modes of applicability.

These changes do not reduce the effectiveness of the Wolf Creek Radiological Emergency Response Plan.

4. Form EPF 06-001-03, SITE AREA EMERGENCY ANNOUNCEMENT, Rev. 005 Form EPF 06-001-03 has been revised. The form is used to ensure the plant site area emergency announcement provides the appropriate instruction for evacuation personnel.

Coffey County and Lyon County have a mutual aid agreement to function as a host county to provide reception and care for evacuees from the effective 10-mile EPZ. The mutual aid agreement has been modified to change the reception center location from the Neosho

Attachment to 000564 Page 3 of 3 Rapids Grade School, located in Neosho Rapids, KS, to the Hartford Jr./Sr. High School, located in Hartford, KS.

Section 3, Option #4 of the form was changed to update the location to evacuate the site for the Lyon County Reception Center from Neosho Rapids to Hartford.

This change does not reduce the effectiveness of the Wolf Creek Radiological Emergency Response Plan.

5. Form EPF 06-001-04, GENERAL EMERGENCY ANNOUNCEMENT, Rev. 004 Form EPF 06-001-04 has been revised. The form is used to ensure the plant general emergency announcement provides the appropriate instruction for evacuation personnel.

Coffey County and Lyon County have a mutual aid agreement to function as a host county to provide reception and care for evacuees from the effective 10-mile EPZ. The mutual aid agreement has been modified to change the reception center location from the Neosho Rapids Grade School, located in Neosho Rapids, KS, to the Hartford Jr./Sr. High School, located in Hartford, KS.

Section 3, Option #1 of the form was changed to update the announcement location for the Lyon County Reception Center from Neosho Rapids to Hartford.

This change does not reduce the effectiveness of the Wolf Creek Radiological Emergency Response Plan.