ML020730745
| ML020730745 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/13/2002 |
| From: | Goshen J NRC/NRR/DLPM |
| To: | Scarola J Carolina Power & Light Co |
| Goshen, JM, NRR/DLPM, 415-1437 | |
| References | |
| TAC MB1911 | |
| Download: ML020730745 (7) | |
Text
Mr. James Scarola, Vice President March 13, 2002 Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - EMERGENCY ACTION LEVEL CHANGES (TAC NO. MB1911)
Dear Mr. Scarola:
By letter dated May 1, 2001, Carolina Power & Light Company (CP&L) submitted proposed changes to the Shearon Harris Nuclear Power Plant (SHNPP) emergency action levels (EALs).
CP&L indicated that EAL Revision 01-1 was submitted for NRC staff review and approval prior to implementation in accordance with Title 10 of the Code of Federal Regulations (10 CFR)
Part 50, Appendix E. The enclosed Safety Evaluation (SE) provides a comparison of the currently approved EALs and the proposed Revision 01-1 as well as a summary of the 10 CFR 50.54(q) evaluation performed by CP&L, which included the basis for the determination that the changes do not decrease the effectiveness of the SHNPP Emergency Plan.
The Nuclear Regulatory Commission has completed its review of the proposed changes and the supporting documentation. We find that the requested changes meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50, and these findings are summarized in the enclosed SE. CP&L stated in the May 1, 2001, letter that these changes were discussed and agreed upon with the appropriate offsite governmental authorities. Therefore, CP&L may implement the proposed changes to the EALs.
Sincerely,
/RA/
John M. Goshen, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-400
Enclosure:
Safety Evaluation cc w/enclosure: See next page
Mr. James Scarola, Vice President March 13, 2002 Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - EMERGENCY ACTION LEVEL CHANGES (TAC NO. MB1911)
Dear Mr. Scarola:
By letter dated May 1, 2001, Carolina Power & Light Company (CP&L) submitted proposed changes to the Shearon Harris Nuclear Power Plant (SHNPP) emergency action levels (EALs).
CP&L indicated that EAL Revision 01-1 was submitted for NRC staff review and approval prior to implementation in accordance with Title 10 of the Code of Federal Regulations (10 CFR)
Part 50, Appendix E. The enclosed Safety Evaluation (SE) provides a comparison of the currently approved EALs and the proposed Revision 01-1 as well as a summary of the 10 CFR 50.54(q) evaluation performed by CP&L, which included the basis for the determination that the changes do not decrease the effectiveness of the SHNPP Emergency Plan.
The Nuclear Regulatory Commission has completed its review of the proposed changes and the supporting documentation. We find that the requested changes meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50, and these findings are summarized in the enclosed SE. CP&L stated in the May 1, 2001, letter that these changes were discussed and agreed upon with the appropriate offsite governmental authorities. Therefore, CP&L may implement the proposed changes to the EALs.
Sincerely,
/RA/
John M. Goshen, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-400
Enclosure:
Safety Evaluation cc w/enclosure: See next page Accession Number ML020730745 DISTRIBUTION :
PUBLIC PDII-2 Rdg.
E. Dunnington (Hard Copy)
JGoshen R. Correia G. Hill (2)
ACRS OC/LFMB H. Berkow OGC B. Bonser, RII P Milligan C Christiansen, RII K Gibson OFFICE PM:PDII/S2 LA:PDII/S2 OGC SC/PDII-2 NAME JGoshen EDunnington SBrock RCorreia DATE 02/27/02 02/27/02 03/05/02 03/11/02 OFFICIAL RECORD COPY SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON PROPOSED CHANGES FOR CAROLINA POWER & LIGHT COMPANY.
SHEARON HARRIS NUCLEAR POWER PLANT EMERGENCY ACTION LEVELS DOCKET NO. 50-400
1.0 INTRODUCTION
This Safety Evaluation (SE) addresses proposed changes to the Shearon Harris Nuclear Power Plant (SHNPP) emergency action levels (EALs) submitted by Carolina Power & Light Company (CP&L, the licensee) in a letter dated May 1, 2001.
2.0 APPLICABLE REGULATIONS AND GUIDANCE Title 10 of the Code of Federal Regulations (10 CFR) Part 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,...
10 CFR Part 50, Appendix E, Section IV.B states, in part:...These emergency action levels shall be discussed and agreed on by the applicant and State and local governmental authorities and approved by the NRC...
Appendix E, Subsection IV.C, to 10 CFR Part 50 states, in part:...Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as pressure in the containment and response of the Emergency Core Cooling System) for notification of offsite agencies shall be described...The emergency classes defined shall include (1) notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency...
Regulatory Guide (RG)1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 2, states, in part: "The criteria and recommendations contained in Revision 1 of NUREG-0654/Federal Emergency Management Agency (FEMA) -REP-1 are considered by the Nuclear Regulatory Commission (NRC) staff to be acceptable methods for complying with the standards in 10 CFR 50.47 that must be met in on-site and off-site emergency response plans."
Section II.D of NUREG-0654/FEMA-REP-1, Rev 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, includes the following criteria for EALs:
- 1.
An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee.
2.
The initiating conditions shall include the example conditions found in Appendix 1
[of NUREG-0654]...
RG 1.101, Revision 3, endorsed Nuclear Management and Resources Council (NUMARC) /
NESP-007, "Methodology for Development of Emergency Action Levels," as an acceptable alternative to NUREG-0654 for developing EAL schemes.
Emergency Preparedness Position No. 1, Emergency Preparedness Position (EPPOS) on Acceptable Deviations from Appendix 1 of NUREG-0654 Based upon the Staff's Regulatory Analysis of NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, dated June 1, 1995, states that licensees could utilize the technical bases under the example (EALs) in NUMARC/NESP-007 to enhance and clarify some of their site-specific EALs developed from NUREG-0654. (The chosen classification scheme, whether based on Appendix 1 to NUREG-0654 or NUMARC/NESP-007, must remain internally consistent.)
3.0 BACKGROUND
In a letter dated May 1, 2001, the licensee requested NRC review and approval of proposed changes to the SHNPP EALs. Enclosure 1 to the letter provided a comparison of the currently approved EALs and proposed Revision 01-1. Enclosure 1 also provided a summary of the 10 CFR 50.54(q) evaluation performed by the licensee, including the basis for the determination that the changes do not decrease the effectiveness of the SHNPP Emergency Plan.
4.0 EVALUATION The licensee grouped the changes in Revision 01-1 into the following three categories:
A. Change Comparison for EAL Flowpath terminus (no event condition identified)
B. Change Assessment - Deletion of EAL 6-2-1 for loss of Emergency Response Facility Information System (ERFIS) Computer C. Change Assessment - Other Administrative and Clerical Changes The proposed changes in these three categories were reviewed using guidance provided in Appendix 1 to NUREG-0654/FEMA-REP-1, Rev.1, NUMARC/NESP-007, Rev. 2 and EPPOS No. 1, Emergency Preparedness Position (EPPOS) on Acceptable Deviations from Appendix 1 of NUREG-0654 Based upon the Staff's Regulatory Analysis of NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, dated June 1, 1995.
4.1 Change Comparison for EAL Flowpath terminus (no event condition identified)
Under this category, the licensee proposed to:
Revise the EAL Flowpath terminus as follows: Deleted ER [Emergency Response]
C-003 and replaced SP-017 with SEC-NGG [Nuclear Generation Group] C-2147."
The licensee indicated that other report ability requirements are referenced at the end of the EAL flowpath in the situation where no emergency declaration condition exists. This is provided as a human factor aid to ensure that other non-Emergency Plan related actions are referenced.
ERC-003 no longer contains any report ability requirements and site procedure SP-017 has been replaced by corporate NGG Procedure SEC-NGGC-2147.
The staff finds that the changes in the flowpath terminus are editorial in nature and are made to make notifications easier and are therefore acceptable.
4.2 Category B - Change Assessment - Deletion of EAL 6-2-1 for Loss of ERFIS Computer The licensee proposed to delete the following EAL:
EAL 6-2-1 for Loss of ERFIS computer.
The licensee references NUMARC/NESP-007 EAL methodology as specifically eliminating the loss of the computer for Safety Parameter Display (SPDS) monitoring as an Unusual Event.
The licensee identified the NUMARC methodology includes unavailability of compensatory computer data for evaluations of the Alert and Site Area Emergency criteria, as does the SHNPP methodology.
The licensee states that Eliminating the loss of ERFIS as criteria requiring an event declaration does not diminish the use of the system for transmission of data to the NRC via the ERDS data link. Also, plant operational and monitoring requirements are not altered in any manner. The operational availability of the system is not being altered as a result of the EAL change.
The licensee also references NRC EPPOS 1, specifically, Other Changes stating in part:
The above changes do not represent a comprehensive list of possible improvements that could be made by utilizing the technical bases in NUMARC/NESP-007. Licensees may provide to the NRC other changes that utilize NESP-007 guidance.
In its review of this EAL revision, the staff considered guidance provided in NUREG-0654, NUMARC/NESP-007 and EPPOS-1.
EPPOS-1 provides the following guidance:
For EALs related to loss of annunciation or indication in the Control Room, licensees may use the technical bases in the following NUMARC/NESP-007 ICs to enhance their classification schemes:
SU3 Unplanned Loss of Most or All Safety System Annunciation or Indication in the Control Room for Greater Than 15 Minutes.
The technical bases state in part: This IC and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.
Recognition of the availability of computer-based indication equipment is considered (SPDS, plant computer, etc.).
Unplanned loss of annunciators or indicator excludes scheduled maintenance and testing activities.
Compensatory non-alarming indications: in this context includes computer-based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits....
The deletion of this indication in the licensees EAL scheme is consistent with the guidance in EPPOS-1 for EALs related to loss of annunciation or indication in the control room. Therefore, the staff concludes that the deletion of the EAL for loss of the ERFIS plant process computer system is acceptable.
4.3 Change Assessment - Other Administrative and Clerical Changes The licensee proposed:
The deletion of the term ERFIS from the Unusual Event Matrix category 6 title is consistent with the deletion of EAL 6-2-1 (loss of ERFIS plant process computer system).
Renumbering of EAL 6-3-1 to 6-2-1 retains consistency in the SHNPP Specific EAL designation protocol.
The staffs review finds that the changes in the title and numbering are editorial in nature and were made to make classification easier. These changes are acceptable.
5.0 STATE AND LOCAL GOVERNMENTAL AGREEMENT In the May 1, 2001, letter, the licensee stated that these proposed EAL changes were discussed and agreed upon by the licensee (CP&L) and State of North Carolina and local governmental authorities as required by 10 CFR Part 50, Appendix E, IV.B.
6.0 CONCLUSION
The proposed revised EALs are consistent with guidance provided in NUREG-0654 and NUMARC/NESP-007. The staff finds that the proposed revised EAL scheme meets the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50 and is acceptable; therefore, the licensee can implement the proposed revision.
Principal Contributor: P. A. Milligan Date:
March 13, 2002
Mr. James Scarola Shearon Harris Nuclear Power Plant Carolina Power & Light Company Unit 1 cc:
Mr. William D. Johnson Mr. Chris L. Burton Vice President and Corporate Secretary Director of Site Operations Carolina Power & Light Company Carolina Power & Light Company Post Office Box 1551 Shearon Harris Nuclear Power Plant Raleigh, North Carolina 27602 Post Office Box 165, MC: Zone 1 New Hill, North Carolina 27562-0165 Resident Inspector/Harris NPS c/o U.S. Nuclear Regulatory Commission Mr. Robert P. Gruber 5421 Shearon Harris Road Executive Director New Hill, North Carolina 27562-9998 Public Staff NCUC Post Office Box 29520 Ms. Karen E. Long Raleigh, North Carolina 27626 Assistant Attorney General State of North Carolina Chairman of the North Carolina Post Office Box 629 Utilities Commission Raleigh, North Carolina 27602 Post Office Box 29510 Raleigh, North Carolina 27626-0510 Public Service Commission State of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211 Ms. Linda Coleman, Chairperson Board of County Commissioners of Wake County P. O. Box 550 Mr. Mel Fry, Director Raleigh, North Carolina 27602 Division of Radiation Protection N.C. Department of Environment and Natural Resources 3825 Barrett Dr.
Mr. Gary Phillips, Chairman Raleigh, North Carolina 27609-7721 Board of County Commissioners of Chatham County P. O. Box 87 Mr. Terry C. Morton Pittsboro, North Carolina 27312 Manager Performance Evaluation and Mr. Richard J. Field, Manager Regulatory Affairs CPB 7 Regulatory Affairs Carolina Power & Light Company Carolina Power & Light Company Post Office Box 1551 Shearon Harris Nuclear Power Plant Raleigh, North Carolina 27602-1551 P.O. Box 165, Mail Zone 1 New Hill, NC 27562-0165 Mr. Robert J. Duncan II Plant General Manager Mr. John R. Caves, Supervisor Carolina Power & Light Company Licensing/Regulatory Programs Shearon Harris Nuclear Power Plant Carolina Power & Light Company P.O. Box 165, Mail Zone 3 Shearon Harris Nuclear Power Plant New Hill, North Carolina 27562-0165 P. O. Box 165, Mail Zone 1 New Hill, NC 27562-0165 Mr. John H. ONeill, Jr.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW.
Washington, DC 20037-1128