ML051860026
| ML051860026 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/19/2005 |
| From: | Michelle Honcharik NRC/NRR/DLPM/LPD4 |
| To: | Edington R Nebraska Public Power District (NPPD) |
| Duvigneaud D, NRR/DLPM/LPD4 301-415-4010 | |
| References | |
| TAC MC5848 | |
| Download: ML051860026 (6) | |
Text
August 19, 2005 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - APPROVAL OF EMERGENCY PLAN REVISION RE: EMERGENCY ACTION LEVEL CHANGE (TAC NO. MC5848)
Dear Mr. Edington:
By letter dated January 28, 2005, Nebraska Public Power District (the licensee) submitted a proposed change to the Cooper Nuclear Station (CNS) Emergency Plan Implementing Procedure 5.7.1. The proposed change to the emergency plan was submitted per the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50. Section 50.54(q), which requires prior U.S. Nuclear Regulatory Commission (NRC) approval for such changes if the licensee cannot conclude that the proposed change does not decrease the effectiveness of the emergency plan. The proposed change relates to an Emergency Action Level (EAL) for the Notification of Unusual Event classification Initiating Condition 1.1.2. The change was proposed due to a pending design change that replaces a radiation monitor in the Multi-Purpose Facility.
As discussed in the enclosed Safety Evaluation, the NRC staff concludes that the proposed revised EAL change meets the applicable requirements of 10 CFR and the requirements of Appendix E to 10 CFR Part 50. Therefore, contingent upon an associated revision to the CNS updated safety analysis report, the proposed revision is acceptable.
Sincerely,
/RA by M. Fields for M.Honcharik/
Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Safety Evaluation cc w/encl: See next page
August 19, 2005 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - APPROVAL OF EMERGENCY PLAN REVISION RE: EMERGENCY ACTION LEVEL CHANGE (TAC NO. MC5848)
Dear Mr. Edington:
By letter dated January 28, 2005, Nebraska Public Power District (the licensee) submitted a proposed change to the Cooper Nuclear Station (CNS) Emergency Plan Implementing Procedure 5.7.1. The proposed change to the emergency plan was submitted per the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50. Section 50.54(q), which requires prior U.S. Nuclear Regulatory Commission (NRC) approval for such changes if the licensee cannot conclude that the proposed change does not decrease the effectiveness of the emergency plan. The proposed change relates to an Emergency Action Level (EAL) for the Notification of Unusual Event classification Initiating Condition 1.1.2. The change was proposed due to a pending design change that replaces a radiation monitor in the Multi-Purpose Facility.
As discussed in the enclosed Safety Evaluation, the NRC staff concludes that the proposed revised EAL change meets the applicable requirements of 10 CFR and the requirements of Appendix E to 10 CFR Part 50. Therefore, contingent upon an associated revision to the CNS updated safety analysis report, the proposed revision is acceptable.
Sincerely,
/RA by M. Fields for M.Honcharik/
Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
PUBLIC PDIV-1 r/f RidsNrrDlpmLpdiv (HBerkow)
RidsNrrDlpmLpdiv1 (DTerao)
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DDuvigneaud DJohnson, NSIR ACCESSION NO: ML051860026 OFFICE PDIV-2/PE PDIV-1/PM PDIV-2/LA NSIR/SC PDIV-1/SC NAME DDuvigneaud MFields for MHoncharik LFeizollahi EWeiss DTerao DATE 8/18/05 8/18/05 8/18/05 08/11/2005 8/19/05
OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EMERGENCY PLAN CHANGES NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION
By letter dated January 28, 2005 (Agencywide Documents Access and Management System (ADAMS) Accession No.: ML050320163), Nebraska Public Power District (the licensee) submitted a proposed change to the Cooper Nuclear Station (CNS) Radiological Emergency Plan Implementing Procedure 5.7.1 and Emergency Action Level (EAL) 1.1.2. This proposed change to the emergency plan was submitted per the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50. Section 50.54(q) requires prior U.S. Nuclear Regulatory Commission (NRC) approval for such changes if the licensee cannot conclude that the proposed change does not decrease the effectiveness of the emergency plan. The change was proposed due to a pending design change that replaces a radiation monitor in the Multi-Purpose Facility (MPF). This design change replaces the existing KAMAN Monitor (RV-RM-10) with a Continuous Air Monitor (CAM).
2.0 APPLICABLE REGULATIONS AND GUIDANCE 2.1 Regulations Part 50.47(b)(4) of 10 CFR 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..."
Part 50 of 10 CFR, Appendix E,Section IV.B states, in part: "... emergency action levels shall be discussed and agreed on by the applicant or licensee and State and local governmental authorities, and approved by the NRC [Nuclear Regulatory Commission]..."
Part 50 of 10 CFR, Appendix E, Subsection IV.C states, in part: "...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 the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described..."
2.2 Guidance Documents Regulatory Guide 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/FEMA-REP-1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans."
NUREG-O654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," (NUREG-0654) includes the following criteria:
Section Il.D.1 - An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee...
Section ll.D.2 - The initiating conditions shall include the example conditions found in Appendix 1 [of NUREG-0654]...
3.0 TECHNICAL EVALUATION
3.1 Licensee's Justification CNS currently uses the NUREG-0654 scheme for emergency classification. The specifics of the proposed change to EAL 1.1.2 for NRC approval is detailed below.
EAL 1.1.2, "Off-site Dose Assessment Manual (ODAM) limits exceeded as indicated by either HIGH-HIGH alarm on a gaseous effluent radiological monitor OR Combined Effluent Monitor indication on SPDS [safety parameter display system] which cannot be cleared within 30 minutes," listed several radioactive effluent monitors, including the MPF Building Vent Hi-Hi Radioactive Monitor, as example EALs for the declaration of this Unusual Event. The licensee proposes the removal of the MPF Building from the example EALs, as well as the removal of a note stating "The MPF is not calculated in the Combined Effluent Monitor display."
The MPF houses decontamination and support equipment used in the maintenance and repair of plant components. Hot machine shop activities are also performed in this facility. The MPF Ventilation Radiation Monitoring System monitors any airborne releases from the MPF to the atmosphere.
The existing MPF monitor (RV-RM-10) is a KAMAN monitor that provides effluent monitoring for activities in the MPF. Particulates, iodine, and noble gases are monitored. This monitor has been experiencing operational problems due to age and obsolescence. The licensee plans on replacing this monitor with a CAM that will continue to monitor particulates and iodine, but not noble gases.
The licensee states that noble gases cannot be generated by any activities within the MPF nor are there any sources that pass through the MPF area that would discharge into the area as the result of an accident. The licensee also states that there are no plans to add such a source to the MPF area. The CNS ODAM Table D.3.3.2-1, "Radioactive Gaseous Effluent Monitoring Instrumentation," and ODAM Table 3-1, "Atmospheric Gaseous Release Points at the Cooper Nuclear Generating Station," do not require a noble gas monitor for the MPF or include the MPF as a gaseous effluent release pathway.
The existing MPF monitor currently provides an annunciator in the CNS Control Room. The proposed CAM replacement only provides a local annunciator. The licensee stated, in response to the requests for additional information (RAI), dated April 6, 2005 (ADAMS Accession No.: ML051810257), that the MPF was originally designed to permit the long-term storage of low-level radioactive waste. The potential for gaseous and particulate releases, if long-term storage of low-level waste were to be incorporated into the MPF building, resulted in the establishment of an annunciator for the MPF. The licensee states that since CNS has no plans currently, or in the foreseeable future, to use the MPF for long-term storage of low-level waste, no remote alarm is necessary.
3.2
NRC Staff Evaluation
The licensee's analysis of the proposed procedural changes is acceptable pending the licensee's revision to its updated safety analysis report (USAR) as referenced below. NRC staff reviewed the submitted material, supplemented by two iterations of RAIs, to determine the acceptability of this proposed change to the EAL.
The licensee had intended to store low-level waste in the MPF per initial design. The current CNS USAR, Chapter XII, Section 2.2.9, reflects this intention. By supplemental letter dated July 27, 2005, the licensee has committed to add the following statement to USAR, Chapter XII:
"There are no plans currently or in the foreseeable future for long-term storage of low level waste in the MPF." Therefore, the licensee no longer has the need for maintaining a radiation effluent system capable of monitoring noble gasses as well as maintaining a radiation effluent system capable of providing remote annunciation.
CNS will continue to maintain a radiation effluent system capable of monitoring particulate and iodine, as well as providing local annunciation capability.
A review of the licensee's ODAM Table D.3.3.2-1 and Table 3-1 justified the licensee's analysis of the suitability of removing the requirement to monitor for noble gasses in the MPF. The ODAM speaks to only requiring particulate and iodine effluent monitoring in the MPF.
The proposed revision to EAL 1.1.2 is acceptable if the proposed revision to the USAR is made concurrently, or before, the proposed revision to EAL 1.1.2. It is unacceptable to revise this EAL prior to revising the USAR.
The proposed change is consistent with the NUREG-0654 emergency class definition for a notice of unusual event (NOUE).
3.3 Licensee Commitment By supplemental letter dated July 27, 2005, the licensee has committed to add the following statement to the CNS USAR, Chapter XII: "There are no plans currently or in the foreseeable future for long-term storage of low level waste in the MPF." This statement will be added to the USAR prior to or concurrent with the implementation of the above Emergency Plan implementing procedure change.
4.0 CONCLUSION
The NRC staff concludes that the licensee's EAL change, as proposed in its letter of January 28, 2005, is acceptable contingent on an associated revision to the CNS USAR. The proposed revised EAL change meets the applicable requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50. Therefore, the proposed EAL change is acceptable.
Principal Contributor: Don A. Johnson Date: August 19, 2005
July 2005 Cooper Nuclear Station cc:
Mr. William J. Fehrman President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. Michael T. Boyce Nuclear Assett Manager Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. John C. McClure Vice President and General Counsel Nebraska Public Power District P. O. Box 499 Columbus, NE 68602-0499 Mr. Paul V. Fleming Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. Michael J. Linder, Director Nebraska Department of Environmental Quality P. O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Ms. Cheryl K. Rogers, Program Manager Nebraska Health & Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P. O. Box 95007 Lincoln, NE 68509-5007 Mr. Mike Wells, Deputy Director Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65101 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Director, Missouri State Emergency Management Agency P. O. Box 116 Jefferson City, MO 65102-0116 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson Suite 310 Topeka, KS 66612-1366 Mr. Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319 Mr. Scott Clardy, Director Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102-0570 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321