RS-20-118, Emergency Plan Addendum Revisions
| ML20272A221 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron  |
| Issue date: | 09/28/2020 |
| From: | Gullott D Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20272A220 | List: |
| References | |
| RS-20-118 | |
| Download: ML20272A221 (11) | |
Text
200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.54(q)(5) 10 CFR 50.4 10 CFR 72.44(f)
RS-20-118 September 28, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. 50-454, 50-455, and 72-68 Dresden Nuclear Power Station, Units 1, 2, and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos.50-010, 50-237, 50-249, and 72-37
Subject:
Exelon Generation Company Emergency Plan Addendum Revisions In accordance with 10 CFR 50.4(b)(5), "Emergency plan and related submissions," Exelon Generation Company, LLC (Exelon) is submitting the Emergency Plan Addendum revisions for the Byron Station (Byron) and Dresden Nuclear Power Station (Dresden) listed in the table below.
Procedure No.
Revision Title EP-AA-1002, Addendum 3 5
Emergency Action Levels for Byron Station EP-AA-1004, Addendum 3 10 Emergency Action Levels for Dresden Station EP-AA-1004, Addendum 3 11 Emergency Action Levels for Dresden Station The changes to the Emergency Plan Addendums cited in the table were evaluated under the requirements of 10 CFR 50.54(q) and were determined not to result in a reduction in the effectiveness of the Emergency Plans for Byron and Dresden. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50.54(q)(5).
The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.
U.S. Nuclear Regulatory Commission Emergency Plan Addendum and Procedure Revisions Docket Nos. 50-454, 50-455, and 72-68,50-010, 50-237, 50-249, and 72-37 September 28, 2020 Page 2 In addition, as required by 10 CFR 50.54(q)(5), this submittal includes a summary analysis of the changes to the noted Emergency Plan Addendum and Procedure (Attachment 1). This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee shall submit a report containing a description of the changes to the Director, Division of Fuel Management, Office of Nuclear Material Safety and Safeguards.
Copies of the Emergency Plan Addendum revisions are included in the attachments to this letter.
There are no regulatory commitments in this submittal.
If you have any questions or require additional information, please contact Amy Hambly at (630) 657-2808.
Respectfully, David M. Gullott Director, Licensing Exelon Generation Company, LLC Attachments:
- 1. 10 CFR 50.54(q)(5) Change Summary Analysis
- 2. EP-AA-1002, Addendum 3, Revision 5, "Emergency Action Levels for Byron Station"
- 3. EP-AA-1004, Addendum 3, Revision 10, "Emergency Action Levels for Dresden Station"
- 4. EP-AA-1004, Addendum 3, Revision 11, "Emergency Action Levels for Dresden Station" cc:
w/ Attachment 1 only Regional Administrator - NRC Region III Director, NRC Division of Spent Fuel Management, ONMSS NRC Senior Resident Inspector - Byron Station NRC Project Manager, NRR - Byron Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety Gullott, David M.
Digitally signed by Gullott, David M.
Date: 2020.09.28 11:41:35 -05'00'
ATTACHMENT 1 10 CFR 50.54(q)(5) Change Summary Analysis Change Summary Analysis Page 1 of 5 ATTACHMENT 1 10 CFR 50.54(q)(5) Change Summary Analysis I.
Document Titles Exelon Generation Company, LLC (Exelon) has issued the following Emergency Plan Addendum revisions for the Byron Station (Byron) and Dresden Nuclear Power Station (Dresden):
EP-AA-1002, Addendum 3, Revision 5, "Emergency Action Levels for Byron Station" EP-AA-1004, Addendum 3, Revision 10, "Emergency Action Levels for Dresden Station" EP-AA-1004, Addendum 3, Revision 11, "Emergency Action Levels for Dresden Station" II.
Description of Procedures Emergency Plan Addendum (EP-AA-1002, Addendum 3)
The Emergency Plan Addendum listed (i.e., EP-AA-1002, Addendum 3) describes the Emergency Action Levels (EALs) implemented at Byron for entering Emergency Classification Levels (ECLs).
Emergency Plan Addendum (EP-AA-1004, Addendum 3)
The Emergency Plan Addendum listed (i.e., EP-AA-1004, Addendum 3) describes the Emergency Action Levels (EALs) implemented at Dresden for entering Emergency Classification Levels (ECLs).
III.
Description of Changes EP-AA-1002, Addendum 3, Revision 5 The following changes were made under this revision to EP-AA-1002, Addendum 3.
By letter dated July 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment Nos. 217 to Renewed Facility Operating License Nos. NPF-37 and NPF-66 for the Byron, Units 1 and 2, respectively. These amendments approved changes submitted in a license amendment request dated August 23, 2019, for revising Emergency Action Level (EAL) RA3.1 to remove specific references to radiation monitoring instrumentation used for monitoring radiation levels in the Main Control Room (MCR) as the only entry condition into the EAL.
This revision to EP-AA-1002, Addendum 3, implements the changes as approved by the NRC in its letter and supporting Safety Evaluation Report (SER) dated July 31, 2020. The changes associated with this revision are considered "conforming changes" and prior NRC approval is not required to support implementation since the changes have already been approved. NRC Regulatory Guide (RG) 1.219, "Guidance on Making Changes to Change Summary Analysis Page 2 of 5 Emergency Plans for Nuclear Power Reactors," states the following regarding "conforming changes":
The licensee should screen all proposed changes to the emergency plan to determine whether a 10 CFR 50.54(q) evaluation is necessary and to determine whether another formal change process is applicable. The purpose of this screening is not to decide which proposed changes could reduce effectiveness but instead whether a 10 CFR 50.54(q) change evaluation is necessary. The licensee should screen each proposed change separately and reserve the treatment of changes collectively for (1) repetitive identical changes, (2) editorial or typographical changes such as formatting, paragraph numbering, spelling, or punctuation that do not change intent, (3) conforming changes, or (4) two or more elements that are interdependent (e.g., a change to one element compensates for a change to another element). The licensee should document this screening if it concludes that a 10 CFR 50.54(q)evaluation is not necessary.
EP-AA-1004, Addendum 3, Revision 10 The following changes were made under this revision to EP-AA-1004, Addendum 3.
By letter dated February 14, 2020, the NRC issued Amendment No. 47 to Facility Operating License DPR-2 for Dresden, Unit 1, and Amendment Nos. 265 and 258 to Renewed Facility Operating License Nos. DPR-19 and DPR-25 for the Dresden, Units 2, and 3, respectively.
These amendments approved changes submitted in a license amendment request dated March 1, 2019, for revising EALs based on adopting certain NRC-accepted Emergency Preparedness Frequently Asked Question (EPFAQ) guidance.
This revision to EP-AA-1004, Addendum 3, implements the changes as approved by the NRC in its letter and supporting SER dated February 14, 2020. The changes associated with this revision are considered "conforming changes" and prior NRC approval is not required to support implementation since the changes have already been approved. NRC RG 1.219 states the following regarding "conforming changes":
The licensee should screen all proposed changes to the emergency plan to determine whether a 10 CFR 50.54(q) evaluation is necessary and to determine whether another formal change process is applicable. The purpose of this screening is not to decide which proposed changes could reduce effectiveness but instead whether a 10 CFR 50.54(q) change evaluation is necessary. The licensee should screen each proposed change separately and reserve the treatment of changes collectively for (1) repetitive identical changes, (2) editorial or typographical changes such as formatting, paragraph numbering, spelling, or punctuation that do not change intent, (3) conforming changes, or (4) two or more elements that are interdependent (e.g., a change to one element compensates for a change to another element). The licensee should document this screening if it concludes that a 10 CFR 50.54(q)evaluation is not necessary.
Change Summary Analysis Page 3 of 5 EP-AA-1004, Addendum 3, Revision 11 The following changes were made under this revision to EP-AA-1004, Addendum 3.
By letter dated July 31, 2020, the NRC issued Amendment No. 49 to Facility Operating License DPR-2 for Dresden, Unit 1, and Amendment Nos. 271 and 264 to Renewed Facility Operating License Nos. DPR-19 and DPR-25 for the Dresden, Units 2, and 3, respectively.
These amendments approved changes submitted in a license amendment request dated August 23, 2019, for revising EAL RA3.1 to remove specific references to radiation monitoring instrumentation used for monitoring radiation levels in the MCR as the only entry condition into the EAL.
This revision to EP-AA-1004, Addendum 3, implements the changes as approved by the NRC in its letter and supporting SER dated July 31, 2020. The changes associated with this revision are considered "conforming changes" and prior NRC approval is not required to support implementation since the changes have already been approved. NRC RG 1.219 states the following regarding "conforming changes":
The licensee should screen all proposed changes to the emergency plan to determine whether a 10 CFR 50.54(q) evaluation is necessary and to determine whether another formal change process is applicable. The purpose of this screening is not to decide which proposed changes could reduce effectiveness but instead whether a 10 CFR 50.54(q) change evaluation is necessary. The licensee should screen each proposed change separately and reserve the treatment of changes collectively for (1) repetitive identical changes, (2) editorial or typographical changes such as formatting, paragraph numbering, spelling, or punctuation that do not change intent, (3) conforming changes, or (4) two or more elements that are interdependent (e.g., a change to one element compensates for a change to another element). The licensee should document this screening if it concludes that a 10 CFR 50.54(q)evaluation is not necessary.
IV.
Description of How the Changes Still Comply with Regulations EP-AA-1002, Addendum 3, Revision 5 Planning Standard 10 CFR 50.47(b)(4) states in part: "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee." In addition, the Program Element guidance in NUREG-0654,Section II.D.1, states in part: "An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures. The plan shall identify the parameter values and equipment status for each emergency class."
The changes made to EAL RA3 in this revision of EP-AA-1002, Addendum 3, as described in Section III above implement Amendment Nos. 217 for Byron, Units 1 and 2, and reflect the changes as approved by the NRC in its letter and supporting SER dated July 31, 2020.
The applicable emergency preparedness regulations and commitments to the NRC continue to be met.
Change Summary Analysis Page 4 of 5 EP-AA-1004, Addendum 3, Revision 10 Planning Standard 10 CFR 50.47(b)(4) states in part: "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee." In addition, Program Element guidance in NUREG-0654,Section II.D.1, states in part: "An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures. The plan shall identify the parameter values and equipment status for each emergency class.
The changes made to the EALs in this revision of EP-AA-1004, Addendum 3, as described in Section III above reflect the implementation of Amendment No. 47 for Dresden, Unit 1, and Amendment Nos. 265 and 258 for Dresden Units 2 and 3, as approved by the NRC in its letter and supporting SER dated February 14, 2020. The applicable emergency preparedness regulations and commitments to the NRC continue to be met.
EP-AA-1004, Addendum 3, Revision 11 Planning Standard 10 CFR 50.47(b)(4) states in part: "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee." In addition, Program Element guidance in NUREG-0654,Section II.D.1, states in part: "An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures. The plan shall identify the parameter values and equipment status for each emergency class.
The changes made to the EAL in this revision of EP-AA-1004, Addendum 3, as described in Section III above reflect the implementation of Amendment No. 49 for Dresden, Unit 1, and Amendment Nos. 271 and 264 for Dresden, Units 2 and 3, as approved by the NRC in its letter and supporting SER dated July 31, 2020. The applicable emergency preparedness regulations and commitments to the NRC continue to be met.
Summary Applicable regulatory commitments made to the NRC continue to be met. Existing requirements and capabilities under the Emergency Plans were not deleted or reduced and applicable regulatory requirements established in 10 CFR 50.47, 10 CFR 50, Appendix E, and the Program Element guidance of NUREG-0654 continue to be met.
V.
Description of Why the Changes are Not a Reduction in Effectiveness (RIE)
Based on the changes described in Sections III and IV above, the emergency response capabilities are maintained and are not adversely impacted. The changes made under these revisions are consistent with changes previously approved by the NRC and were determined not to require prior NRC approval since they involved "conforming changes."
The changes made were also consistent with the guidance specified described in RG 1.219.
Change Summary Analysis Page 5 of 5 Applicable emergency preparedness regulatory commitments made to the NRC and applicable regulatory requirements established in 10 CFR 50.47, 10 CFR 50, Appendix E, and the Program Element guidance of NUREG-0654 continue to be met. Therefore, the changes described do not constitute a reduction in effectiveness of the Emergency Plans for Byron and Dresden.
ATTACHMENT 2 Radiological Emergency Plan Addendum Revision EP-AA-1002, Addendum 3, Revision 5, "Emergency Action Levels for Byron Station"
ATTACHMENT 3 Radiological Emergency Plan Addendum Revision EP-AA-1004, Addendum 3, Revision 10, "Emergency Action Levels for Dresden Station"
ATTACHMENT 4 Radiological Emergency Plan Procedure Revision EP-AA-1004, Addendum 3, Revision 11, "Emergency Action Levels for Dresden Station"