ULNRC-05336, Revisions 28 and 29 to Radiological Emergency Response Plan Emergency Action Levels 3I & 3J

Revisions 28 and 29 to Radiological Emergency Response Plan Emergency Action Levels 3I & 3J

ML062850223
Person / Time
Site:	Callaway
Issue date:	10/03/2006
From:	Keith Young AmerenUE, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-05336
Download: ML062850223 (6)

Text

AmerenUE P0 Box 620 Ca/Iaway Plant Fulton, M0 65251 October 3, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC-05336 WAmereen Ladies and Gentlemen:

UI DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 EMERGENCY PREPAREDNESS This letter requests pre-approval of a proposed change to the CallawayPlant Radiological Emergency Response Plan (RERP) Emergency Action Levels 31 and 3J.

This revision is being made per discussions with NRC Region IV personnel to correct overly conservative initiating conditions in our current EAL scheme based on the definition of a hazardous atmosphere in CDP-ZZ-0 1100, which is referenced in the current EAL indicators.

This change was discussed with NRC Region IV personnel during a teleconference brief on September 21, 2006. The current EALs have been revised based on the NEI 99-01 Rev. 4, HU3 and HA3 guidance, staying as close as possible to the exact verbiage in the document. In addition, verbiage pertaining to asphyxiates has been added to address a new FAQ scheduled for issue to modify the wording in HU3 and HA3 to include asphyxiates as an element in the EALs.

This change represents an improvement in our current EAL indicators for 31 and 3J that will prevent unnecessary Unusual Event and Alert declarations at the site. The change also meets current NRC industry excepted standards. Per discussions during the September 21, 2006 brief, this change represents a reduction of effectiveness per 1 OCFR50.54(q) due to our current EAL initiating conditions being reached at a more conservative indicating level than that set forth in NEI 99-01 Rev. 4 guidance.

Callaway Plant hereby requests an expeditious review and approval of this proposed change to the RERP.

Attached are the current copy (Revision 28) and the proposed changes (Revision 29) of the 31 and 3J EALs from Table 4-1 of the RERP.

74L5 a subsidiary of Ameren Corporation

ULNRC05336 October 3, 2006 Page 2 The Callaway Onsite Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the attached proposed RERP revision and have approved the submittal of this request for NRC pre-approval of the proposed change to the RERP.

If you have any questions or require additional information, please contact Luke H.

Graessle, Superintendent, Protective Services, at 573-676-8129.

Sincerely, 14 Keith D. Young Manager, Regulatory Affairs KDY/DES/DJW/slk Executed on October 3, 2006.

Enclosures:

RERP Table 4-1, Revision 28 (current)

RERP Table 4-1, Revision 29 (proposed)

ULNRC05336 October 3 2006 Page 3 cc:

Mr. Bruce S. Mallett (2 copies)

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Senior Emergency Preparedness Analyst U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

ULNRC05336 October 3 2006 Page 4 bcc:

C. D. Naslund A. C. Heflin K. D. Young D. E. Shafer (470)

S. L. Gallagher (100)

L. M. Belsky (NSRB)

K. A. Mills P. M. Bell D. J. Walker A160.0761 Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and public disclosed).

Send the following without attachments:

Ms. Diane M. Hooper Supervisor, Licensing WCNOC P.O. Box 411 Burlington, KS 66839 Mr. Scott Bauer Regulatory Affairs Palo Verde NGS P.O. Box 52034, Mail Station 7636 Phoenix, AZ 85072-2034 Mr. Scott Head Supervisor, Licensing South Texas Project NOC Mail Code N5014 P.O. Box 289 Wadsworth, TX 77483 Mr. Dennis Buschbaum TXU Power Comanche Peak SES P.O. Box 1002 Glen Rose, TX 76043 Mr. Stan Ketelsen Manager, Regulatory Services Pacific Gas & Electric Mail Stop 104/5/536 P.O. Box 56 Avila Beach, CA 93424 Mr. John O'Neill Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street N.W.

Washington, DC 20037

Table 4-1 EMERGENCY ACTION LEVELS S.

Group 3 HAZARDS AFFECTING PLANT SAFETY Toxic Gas UNUSUAL EVENT I

ALERT

1.

J.

Release of Toxic or Flammable Gases Release of Toxic or Flammable Gases Deemed Detrimental to Safe Operation Within a Facility Structure Which of the Plant.

Jeopardizes Operation of Systems Required to Establish or Maintain Cold Shutdown.

MODES: At All Times MODES: At All Times Indicators Indicators Any of the following:

Any of the following:

1. Report or detection of toxic or

1. Report or detection of toxic or flammable gases that enter within flammable gases, not properly the Exclusion Area Boundary, that contained, within or adjacent to any have created a HAZARDOUS of the following Safe Shutdown ATMOSPHERE per Areas, that have created a CDP-ZZ-01100, deemed HAZARDOUS ATMOSPHERE detrimental to safe operation.

per CDP-ZZ-01100, jeopardizing

2.

Confirmed report by local, County operation of systems required to or State Officials of potential establish or maintain Cold evacuation of site personnel as Shutdown determined from the DOT evacuation tables for selected 0 Area 5 hazardous materials in the DOT 0 Containment Emergency Response Guide for 0 Aux Feed Pump Rooms Hazardous Materials.

Aux Building Diesel Generator Building 0 UHS Cooling Tower ESW Pumphouse

• Control Building

• RWST

• Fuel Building Control Room Evacuation Events ALERT SITE EMERGENCY K.

L.

Control Room Evacuation Has Been Control Room Evacuation Has Been Initiated.

Initiated and Plant Control Cannot Be Established.

MODES: At All Times MODES: At All Times Indicators Indicators Entry into OTO-ZZ-00001, Control

1. Entry into OTO-ZZ-00001, Room Inaccessibility, is required.

Control Room Inaccessibility, is required.

and

2.

Control of the Aux Feed System and a SG PORV for cooldown cannot be established within 15 minutes.

Page 6 of 10 RERP Rev. 028 05/06

Table 4-1 EMERGENCY ACTION LEVELS Group 3 HAZARDS AFFECTING PLANT SAFETY Toxic Gas UNTJSUAL EVENT ALERT I.

J.

Release of Toxic, Asphyxiating OR Release of Toxic, Asphyxiating OR Flammable Gases Deemed Detrimental Flammable Gases Within OR to Normal Operation of the Plant.

Contiguous to a SAFE SHUTDOWN AREA Which Jeopardizes Operation of Systems Required to Maintain Safe MODES: At All Times Operations OR Establish OR Maintain Safe Shutdown.

MODES: At All Times Indicators Indicators Any of the following:

Any of the following:

1. Report OR detection of toxic, I.

Report OR detection of toxic OR asphyxiating OR flammable gases asphyxiating gases within or that enter within the Exclusion contiguous to a SAFE SHUTDOWN AREA in concentrations that may Area Boundary in amounts that can result in an atmosphere affect Normal Plant Operations.

IMMEDIATELY DANGEROUS TO LIFE AND HEALTH (IDLH).

2.

Confirmed report by local, County

2.

Report or detection of gases in OR State Officials for evacuation concentrations greater than the OR Sheltering of site personnel LOWER FLAMMABILITY LIMIT based on an offsite event, within or contiguous to a SAFE SHUTDOWN AREA.

SAFE SHUTDOWN AREAs Area 5 Containment Aux Feed Pump Rooms Aux Building Diesel Generator Buildings UIIS Cooling Tower ESW Pumphouse Control Building RWST Fuel Building Control Room Evacuation Events ALERT f

SITE EMERGENCY K.

L.

Control Room Evacuation Has Been Control Room Evacuation Has Been Initiated.

Initiated and Plant Control Cannot Be Established.

MODES: At All Times MODES: At All Times Indicators Indicators Entry into OTO-ZZ-00001, Control

1. Entry into OTO-ZZ-00001, Room Inaccessibility, is required.

Control Room Inaccessibility, is required.

and

2.

Control of the Aux Feed System and a SG PORV for cooldown cannot be established within 15 minutes.

Page 6 ofl0 RERP Rev. 029 09/06