ML24211A171

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Associated Independent Spent Fuels Storage Installation, Revision to Emergency Plan - Report of Change
ML24211A171
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 07/25/2024
From: James Holloway
Dominion Energy Nuclear Connecticut
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
24-248
Download: ML24211A171 (1)


Text

Dominion Energy Nuciear Connecticut, Inc.

5000 Domirnon Boulevard, Glen Alien, VA 23060 DominionEnergy.com ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 July 25, 2024 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 1, 2, 31 AND

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Dominion

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Energy' Serial No.:

24-248 NLOS /TFO:

RO Docket Nos.:

50-245/

336/423 72-47 License Nos.:

DPR-21/65 NPF-49 ASSOCIATED INDEPENDENT SPENT FUEL STORAGE INSTALLATION REVISION TO EMERGENCY PLAN - REPORT OF CHANGE Pursuant to 10 CFR 50.54(q)(5) and 10 CFR 72.44(f), a summary of the change analysis for Revision 67 of the Millstone Power Station (MPS) Emergency Plan is provided in the attachment. Additionally, a summary of the change analysis for a subsequent update to the Emergency Action Limits (EALs) to incorporate NUHOMS EOS System Horizontal Storage Module (EOS-HSM) is provided in the attachment.

Revision 67 of the MPS Emergency Plan made changes to the periodicity and responsibility for Emergency Response Organization (ERO) Augmentation Capability Assessment (ACA) surveillances and was made effective on August 8, 2023.

The changes incorporated in the revision did not require prior NRC approval and do not implement actions that reduce the effectiveness of the MPS Emergency Plan. The MPS Emergency Plan continues to meet the standards of 10 CFR 50.47(b) and Appendix E.

10 CFR 50.54(q)(5) requires licensees report changes made to the emergency plan not requiring prior NRC approval within 30 days after the change is put into effect. Condition Report CR1264628 has been entered into the Corrective Action Program to document Revision 67 not meeting the 30-day reporting requirement.

An update to the Emergency Action Limits (EALs) was made to incorporate NUHOMS EOS System Horizontal Storage Module (EOS-HSM) and was made effective on June 26, 2024. The changes incorporated did not require prior NRC approval and do not implement actions that reduce the effectiveness of the MPS Emergency Plan. The MPS Emergency Plan continues to meet the standards of 10 CFR 50.47(b) and Appendix E.

Serial No.: 24-248 Docket Nos.: 50-245/336/423 72-47 Page 2 of3 If you have any questions or require additional information, please contact Lori K. Kelley at 860-44 7-1791, extension 6520.

Sincerely, James E. Holloway Vice President - Nuclear Engineering & Fleet Support Commitments made by this letter: None

Attachment:

Millstone Power Station Emergency Plan Change, 10 CFR 50.54(q)(5) Summaries

cc:

Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road, Suite 102 King of Prussia, Pennsylvania 19406-1415 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Richard. V. Guzman NRG Senior Project Manager - (MPS Units 2 and 3)

U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 9 E3 11555 Rockville Pike Rockville, Maryland 20852-2738 Tonya E. Hood Decommissioning Project Manager (MPS Unit 1)

U.S. Nuclear Regulatory Commission Two White Flint North Mail Stop A 1 OM 11545 Rockville Pike Rockville, MD 20852-2738 Yen-Ju J. Chen NRG Senior Project Manager - ISFSls U. S. Nuclear Regulatory Commission Mail Stop 834M Two White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector Millstone Power Station Serial No.: 24-248 Docket Nos.: 50-245/336/423 72-47 Page 3 of 3

ATTACHMENT Serial No.: 24-248 Docket Nos.: 50-245/336/423 72-47 Millstone Power Station Emergency Plan Change 10 CFR 50.54(q)(5} Summaries DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 1, 2 AND 3 MILLSTONE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Serial No.: 24-248 Docket Nos.: 50-245/336/423 72-47 Attachment, Page 1 of 2 Millstone Power Station Emergency Plan Change, 10 CFR 50.54{g)(5) Summaries 10 CFR 50.54(q)(5) Summary for Revision 67 of the Emergency Plan:

The Millstone Power Station (MPS) Emergency Plan Revision 67 incorporated the changes described below. A description of why each change was not a reduction in the effectiveness of the emergency plan and the regulatory basis are provided below.

The frequency of the Emergency Response Organization (ERO)

Augmentation Capability Assessment (ACA) surveillance was revised from monthly to quarterly. Additionally, Corporate Emergency Planning assumes responsibility for conducting the ACA surveillance of Millstone's minimum staff positions. These changes affected procedures C SP 600.2, C SP 600.2-002, EP-AA-106, and the Emergency Plan (MP-26-EPI-EPMP).

Procedure C SP 600.2-002 - ERO Augmentation Capability Assessment, was deleted and quarterly testing is specified by a new Fleet procedure, EP-AA-106 - ERO Augmentation Drill Performance and Reporting.

10 CFR 50.47 and Appendix E do not specifically define the periodicity requirements for ERO Call-In drills (ACA drills). Additionally, Revision 1 of NUREG-0654 does not specifically define the periodicity requirements, but it is implied that surveillances be performed quarterly in Sections F.3 and H.10. While the Dominion Fleet has not yet adopted Revision 2 of NUREG-0654/FEMA-REP-1, the guidance in the document specifically identifies that drills should be conducted quarterly. (N.4.h - Off-Hours Call-In Drills. Off-hours call-in drills are conducted at least quarterly, such that each ERO member's response time is validated at least biennially. Some drills are unannounced).

This change was made to assist the Corporate Response Center personnel who support all four Dominion stations, and therefore receive four ACA drills each month. This change will allow a reasonable number of drills for Corporate ERO members who cover multiple sites. The requirements of 10 CFR 50.47(b)(1), (b)(2), (b)(5), and NUREG-0654/FEMA-REP-1 Revision 1 (E)(2), (F)(1)(e), (H)(4), (H)(10), and 10 CFR 50 Appendix E, Part IV F1.

and F2. continue to be met. Thus, the effectiveness of the MPS Emergency Plan is maintained.

Serial No.: 24-248 Docket Nos.: 50-245/336/423 72-47 Attachment, Page 2 of 2 10 CFR 50.54(q)(5) Summary for revision to the Emergency Action Limits:

MPS Unit 2 and Unit 3 Emergency Action Limits (EALs) (Revisions 17 and 13, respectively) and associated Technical Bases (Revisions 33 and 28, respectively) documents incorporated the changes described below. A description of why each change was not a reduction in the effectiveness of the emergency plan and the regulatory basis are provided.

  • A revision to the MPS Unit 2 and Unit 3 EAL Tables and associated bases documents went into effect on June 26, 2024. Specifically, a revision was made to criteria for the Independent Spent Fuel Storage Installation (ISFSI)

EAL, EU1.1. A new model cask is being used to support the upcoming ISFSI campaign in July. The dose rate criteria in EU1.1 required revision based on the design of the new model cask. An EAL table was added which includes the current model (HSM-152) dose rate criteria and the new model (NUHOMS EOS System Horizontal Storage Module (EOS-HSM) and model EOS-37PTH type 2 dry storage cask (DSC)) dose rate criteria.

The revision to the EAL Tables for EAL EU1.1 and associated Technical Bases documents include dose rate limits for the EOS-HSM cask. The updated EALs continue to provide and maintain criteria and capabilities to determine, assess, and classify an event involving the ISFSI that are equivalent to the previous EAL thresholds and criteria that were approved for use by NEI 99-01 Revision 6 Amendments (ADAMS Accession No ML193050248) for MPS Units 1, 2, and 3. The emergency planning standard for assessing plant conditions per 10 CFR 50.47(b)(4), 10 CFR 50 Appendix E, Section IV.B.1, and NUREG-0654, and the emergency planning standard for classifying events per 10 CFR 50.47(b)(9), continue to be met.

The Engineering Technical Evaluation supporting the change in cask design was added as a reference in the EAL. Millstone received approval to use the EOS-HSM cask in the Millstone Power Station ISFSI Certificate of Compliance 1042 Amendment 2, including Technical Specifications. The emergency planning standard for assessing plant conditions per 10 CFR 50.47(b)(4), 10 CFR 50 Appendix E, Section IV.B.1, and NUREG-0654, and the emergency planning standard for classifying events per 10 CFR 50.47(b)(9), continue to be met.