ML25181A060

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Revision of One Form That Implements the Radiological Emergency Response Plan (RERP)
ML25181A060
Person / Time
Site: Wolf Creek, Peach Bottom  Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 06/30/2025
From: Galati F
Wolf Creek
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
001046
Download: ML25181A060 (1)


Text

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831 Frank V. Galati Acting Director Nuclear and Regulatory Affairs June 30, 2025 001046 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Reference:

Letter 000736, dated December 12, 2024, from D.T. Hamman, WCNOC, to USNRC, Revision of One Form that Implements the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (ADAMS No. ML24347A012)

Subject:

Docket Nos. 50-482 and 72-79: Revision of One Form that Implements 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), Wolf Creek Nuclear Operating Corporation (WCNOC) submitted the Reference which previously notified the Nuclear Regulatory Commission (NRC) of a change to the Radiological Emergency Response Plan (RERP) Form APF 06-002-02, Revision 3. APF 06-002-02, Revision 3 was released on December 4, 2024.

On January 27, 2025, WCNOC identified that a change was inadvertently included in Revision 3 of APF 06-002-02, and the change was not included in the supporting change documentation.

This was documented in Wolf Creek Generating Stations (WCGSs) Corrective Action Program in Condition Report (CR) 10039349.

To address this issue, a supplemental correction was issued for APF 06-002-02, Revision 3 on February 11, 2025, for the associated Document Revision Request. This correction included a new Applicability Determination, 50.54(q) screening, and 50.54(q) effectiveness evaluation to properly document the change, as described in CR 10039349.

During the Emergency Planning Biennial Exercise and Performance Indicator Inspection conducted the week of June 5, 2025, it was identified that although the documentation issue had been corrected in February, a follow-up letter had not been submitted to the NRC within 30 days, as required by 10 CFR 50.54(q)(5). This oversight was documented in WCGSs Corrective Action Program in CR 10042133.

Accordingly, and in compliance with 10 CFR 50.54(q)(5) and 10 CFR 72.44(f), WCNOC is hereby submitting this notification of the change to the emergency plan. The revised document is summarized below:

Form Initial Rev. 3 Effective Date Correction Effective Date APF 06-002-02, Rev. 3 December 04, 2024 February 11, 2025 Wolf Creek~lj Nuclear Operating Corporation

001046 Page 2 of 2 The attached summary of changes to the implementing form demonstrates that the revision does 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, Frank V. Galati Acting Director Nuclear and Regulatory Affairs FVG/jkt

Attachment:

Summary of Changes to One Form that Implements the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS) cc:

A. N. Agrawal (NRC), w/a S. S. Lee (NRC), w/a J. D. Monninger, (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 25-001046, w/a

Attachment to 001046 Page 1 of 1 Summary of Changes to One Form that Implements the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS)

1. Procedure Form APF 06-002-02, Emergency Action Levels Technical Bases, Rev. 3 Supplemental Correction Procedure Form APF 06-002-02 has been revised. This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Wolf Creek Generating Station (WCGS). The technical bases may be used as a technical reference for EAL interpretation in support of decision-makers who are responsible for making event classification.

APF 06-002-02 was updated to clarify when a power source can be credited as an available source for the NB (Low Medium Voltage System 4.16 kV) bus. An offsite power source is credited as capable of supplying power, only after the offsite source is supplying AC power to an NB bus. This clarification was needed to ensure the approved EAL Matrix is implemented as it was originally approved in License Amendment No. 218. CR 10024149 was written to track this change.

On pages 108 and 173, new guidance was added to clarify when a source can be credited as an available source for an NB bus. On pages 109 and 174, License Amendment No. 218, RAI-WCGS-5 was added as a reference. The change clearly states when an offsite AC power source is available.

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

The Reference includes a summary of the other changes implemented in APF 06-002-02, Revision 3, which was released on December 4, 2024. The changes discussed in the Reference did not reduce the effectiveness of the WCGS Radiological Emergency Response Plan.