ML081430077

Conference Call with Dominion Regarding Proposed Changes to the Radiological Emergency Response Plan for Kewaunee Power Station

ML081430077
Person / Time
Site:	Kewaunee
Issue date:	06/02/2008
From:	Chernoff M NRC/NRR/ADRO/DORL/LPLIII-1
To:	Lois James NRC/NRR/ADRO/DORL/LPLIII-1
Chernoff M, NRR/DORL, 415-4041
References
Download: ML081430077 (3)

Text

June 2, 2008 MEMORANDUM TO: Lois James, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing FROM: Margaret H. Chernoff, Senior Project Manager /RA/

Plant Licensing Branch III-1 Division of Operating Reactor Licensing

SUBJECT:

KEWAUNEE POWER STATION - CONFERENCE CALL WITH DOMINION REGARDING PROPOSED CHANGES TO THE RADIOLOGICAL EMERGENCY RESPONSE PLAN On May 15, 2008, a conference call was held with Dominion to discuss the regulatory evaluation criteria applicable to some proposed changes to the Radiological Emergency Response Plan for the Kewaunee Power Station. Attendees for Division of Operating Reactor Licensing were Harold Chernoff, Rick Ennis, and Margaret Chernoff. Representatives for Dominion were Dave Sommers, Craig Sly, Paul Serra, and John Costello.

The licensee described three proposed changes to Emergency Action Levels (EAL). The Nuclear Regulatory Commission (NRC) staff pointed out that licensees may make changes to the emergency plan without prior approval, provided that the changes do not decrease the effectiveness of the plan, and the plan as revised continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. Additionally, the specific criteria for determining if a revision to an emergency action level must be approved by the NRC prior to implementation is contained in Section IV.B of 10 CFR Part 50, Appendix E. Prior approval is required if the proposed EAL change involves a change in the EAL scheme, an alternate method of complying with the regulations, or if the revision decreases the effectiveness of the emergency plan. Additional insights for determining the existence of a decrease in effectiveness may be found in Regulatory Issue Summary (RIS) 2005-02, Clarifying the Process for Making Emergency Plan Changes, and RIS 2003-018, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels.

The NRC staff advised the licensee to perform a thorough evaluation of the proposed change per the applicable regulatory criteria in 10 CFR 50.47 and 10 CFR Part 50, Appendix E, and the guidance in RIS 2005-02. The evaluation would determine whether NRC approval prior to implementation is necessary.

The NRC staff noted that whether a proposed change constitutes a decrease in effectiveness is a determination that needs to be made by the licensee, not the NRC, since it is solely a threshold to determine if prior approval is needed (i.e., its not an acceptance criteria). The NRCs acceptance criteria relates to whether the proposed change provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Docket No. 50-305

MEMORANDUM TO: Lois James, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing FROM: Margaret H. Chernoff, Senior Project Manager /RA/

Plant Licensing Branch III-1 Division of Operating Reactor Licensing

SUBJECT:

KEWAUNEE POWER STATION - CONFERENCE CALL WITH DOMINION REGARDING PROPOSED CHANGES TO THE RADIOLOGICAL EMERGENCY RESPONSE PLAN On May 15, 2008, a conference call was held with Dominion to discuss the regulatory evaluation criteria applicable to some proposed changes to the Radiological Emergency Response Plan for the Kewaunee Power Station. Attendees for Division of Operating Reactor Licensing were Harold Chernoff, Rick Ennis, and Margaret Chernoff. Representatives for Dominion were Dave Sommers, Craig Sly, Paul Serra, and John Costello.

The licensee described three proposed changes to Emergency Action Levels (EAL). The Nuclear Regulatory Commission (NRC) staff pointed out that licensees may make changes to the emergency plan without prior approval, provided that the changes do not decrease the effectiveness of the plan, and the plan as revised continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. Additionally, the specific criteria for determining if a revision to an emergency action level must be approved by the NRC prior to implementation is contained in Section IV.B of 10 CFR Part 50, Appendix E. Prior approval is required if the proposed EAL change involves a change in the EAL scheme, an alternate method of complying with the regulations, or if the revision decreases the effectiveness of the emergency plan. Additional insights for determining the existence of a decrease in effectiveness may be found in Regulatory Issue Summary (RIS) 2005-02, Clarifying the Process for Making Emergency Plan Changes, and RIS 2003-018, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels.

The NRC staff advised the licensee to perform a thorough evaluation of the proposed change per the applicable regulatory criteria in 10 CFR 50.47 and 10 CFR Part 50, Appendix E, and the guidance in RIS 2005-02. The evaluation would determine whether NRC approval prior to implementation is necessary.

The NRC staff noted that whether a proposed change constitutes a decrease in effectiveness is a determination that needs to be made by the licensee, not the NRC, since it is solely a threshold to determine if prior approval is needed (i.e., its not an acceptance criteria). The NRCs acceptance criteria relates to whether the proposed change provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Docket No. 50-305 DISTRIBUTION:

PUBLIC RidsNrrPMMChernoff REnnis, NRR LPL3-1 r/f RidsNrrLATHarris JCushing, NRR RidsNrrDorlLpl3-1 HChernoff, NRR LJames, NRR ADAMS ACCESSION NUMBER: ML081430077 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/LPL3-1/BC NAME Mchernoff THarris LJames DATE 06/3/08 05/29/08 06/2/08 OFFICIAL COPY

Kewaunee Power Station cc:

Resident Inspectors Office Ms. Lillian M. Cuoco, Esq.

U.S. Nuclear Regulatory Commission Senior Counsel N490 Hwy 42 Dominion Resources Services, Inc.

Kewaunee, WI 54216-9510 120 Tredegar Street Riverside 2 Mr. Chris L. Funderburk Richmond, VA 23219 Director, Nuclear Licensing and Operations Support Mr. Stephen E. Scace Innsbrook Technical Center Site Vice President 5000 Dominion Boulevard Dominion Energy Kewaunee, inc.

Glen Allen, VA 23060-6711 Kewaunee Power Station N 490 Highway 42 Mr. Thomas L. Breene Kewaunee, WI 54216 Dominon Energy Kewaunee, Inc.

Kewaunee Power Station Mr. Thomas J. Webb, Director N490 Highway 42 Nuclear Safety & Licensing Kewaunee, WI 54216 Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N 490 Highway 42 Kewaunee, WI 54216