ML052640254
| ML052640254 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 10/18/2005 |
| From: | Raghavan L NRC/NRR/DLPM/LPD3 |
| To: | Peifer M Nuclear Management Co |
| Beltz T, NRR/ DLPM, 301-415-3049 | |
| References | |
| RIS-03-018, TAC MC4956 | |
| Download: ML052640254 (8) | |
See also: RIS 2003-18
Text
October 18, 2005
Mr. Mark A. Peifer
Site Vice President
Duane Arnold Energy Center
Nuclear Management Company, LLC
3277 DAEC Road
Palo, IA 52324-0351
SUBJECT:
DUANE ARNOLD ENERGY CENTER - ISSUANCE OF APPROVAL OF THE
UPGRADED EMERGENCY ACTION LEVEL PLANS BASED ON REVISION 4
TO NUCLEAR ENERGY INSTITUTE (NEI) 99-01 (TAC NO. MC4956)
Dear Mr. Peifer:
By letter to the Nuclear Regulatory Commission (NRC) dated October 22, 2004, as
supplemented by letter dated June 24, 2005, Nuclear Management Company, LLC, requested
the NRC staff review and approve changes to the emergency action levels (EALs) for the
Duane Arnold Energy Center (DAEC) as required by Title 10 of the Code of Federal
Regulations, Part 50 (10 CFR), Appendix E,Section IV.B and 10 CFR 50.47(b).
The proposed changes revise the DAEC EALs to implement the guidance outlined in
NEI 99-01, Methodology for Development of Emergency Action Levels (Revision 4,
January 2003). NEI 99-01 has been endorsed by the NRC staff under Revision 4 of Regulatory
Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors (July 2003)
and in NRC Regulatory Issue Summary 2003-18, Use of NEI 99-01, Methodology for
Development of Emergency Action Levels, dated October 8, 2003.
The NRC staff has reviewed the revised EALs, as documented in the enclosed Safety
Evaluation. The NRC staff finds that the proposed DAEC EAL revisions are consistent with the
guidance in NEI 99-01, Revision 4, or provide an acceptable alternative. As a result, the
revised EALs will continue to satisfy the criteria of Appendix E to 10 CFR Part 50 as well as
10 CFR 50.47(b) and are, therefore, acceptable.
Sincerely,
/RA/
L. Raghavan, Chief, Section 1
Project Directorate III
Division of Licensing Project Management
Office of Nuclear Reactor Regulation
Docket No. 50-331
Enclosure: Safety Evaluation
cc w/encl: See next page
October 18, 2005
Mr. Mark A. Peifer
Site Vice President
Duane Arnold Energy Center
Nuclear Management Company, LLC
3277 DAEC Road
Palo, IA 52324-0351
SUBJECT:
DUANE ARNOLD ENERGY CENTER - ISSUANCE OF APPROVAL OF THE
UPGRADED EMERGENCY ACTION LEVEL PLANS BASED ON REVISION 4
TO NUCLEAR ENERGY INSTITUTE (NEI) 99-01 (TAC NO. MC4956)
Dear Mr. Peifer:
By letter to the Nuclear Regulatory Commission (NRC) dated October 22, 2004, as
supplemented by letter dated June 24, 2005, Nuclear Management Company, LLC, requested
the NRC staff review and approve changes to the emergency action levels (EALs) for the
Duane Arnold Energy Center (DAEC) as required by Title 10 of the Code of Federal
Regulations, Part 50 (10 CFR), Appendix E,Section IV.B and 10 CFR 50.47(b).
The proposed changes revise the DAEC EALs to implement the guidance outlined in
NEI 99-01, Methodology for Development of Emergency Action Levels (Revision 4,
January 2003). NEI 99-01 has been endorsed by the NRC staff under Revision 4 of Regulatory
Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors (July 2003)
and in NRC Regulatory Issue Summary 2003-18, Use of NEI 99-01, Methodology for
Development of Emergency Action Levels, dated October 8, 2003.
The NRC staff has reviewed the revised EALs, as documented in the enclosed Safety
Evaluation. The NRC staff finds that the proposed DAEC EAL revisions are consistent with the
guidance in NEI 99-01, Revision 4, or provide an acceptable alternative. As a result, the
revised EALs will continue to satisfy the criteria of Appendix E to 10 CFR Part 50 as well as
10 CFR 50.47(b) and are, therefore, acceptable.
Sincerely,
/RA/
L. Raghavan, Chief, Section 1
Project Directorate III
Division of Licensing Project Management
Office of Nuclear Reactor Regulation
Docket No. 50-331
Enclosure: Safety Evaluation
cc w/encl: See next page
DISTRIBUTION:
PUBLIC
PDIII-1 R/F
DSpaulding
DBarss
LRaghavan
THarris
EWeiss
JAnderson
BBurgess, RGN III
ADAMS Accession Number: ML052640254
OFFICE
PDIII-1/PM
PDIII-1/PM
PDIII-1/LA
NSIR/DPR/EPD/SC
PDIII-1/SC
NAME
TBeltz
TBeltz for DSpaulding
THarris
EWeiss
MWoods
LRaghavan
DATE
10/14/05
10/14/05
10/14/05
08/10/05
10/14/05
10/18/05
OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO PROPOSED EMERGENCY ACTION LEVELS BASED ON REVISION 4 TO
NUCLEAR ENERGY INSTITUTE 99-01, METHODOLOGY FOR DEVELOPMENT OF
EMERGENCY ACTION LEVELS
NUCLEAR MANAGEMENT COMPANY, LLC
DUANE ARNOLD ENERGY CENTER
DOCKET NO. 50-331
1.0 INTRODUCTION
By application to the Nuclear Regulatory Commission (NRC) dated October 22, 2004
(Reference 1), Nuclear Management Company, LLC, (NMC or the licensee) requested changes
to the emergency action levels (EALs) for the Duane Arnold Energy Center (DAEC). The
licensee responded to the NRC staffs June 3, 2005 (Reference 2), request for additional
information on June 24, 2005 (Reference 3), and provided a complete revision to the proposed
DAEC EAL scheme. The additional information in Reference 3 provided application
clarification, but did not expand the scope of the application as originally submitted. The
proposed changes will revise the DAEC EALs to implement the guidance in Revision 4 to
Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action
Levels, issued in January 2003, which was endorsed by the NRC in Revision 4 to Regulatory
Guide (RG) 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors,
issued in July 2003.
2.0 REGULATORY EVALUATION
The applicable regulations and guidance that the licensee must meet for the Emergency Plans,
and changes to EALs, are described below:
2.1 Regulations
Paragraph (a)(1) to Section 50.47, Emergency Plans, of Title 10 of the Code of Federal
Regulations (10 CFR) Part 50 states that no operating license for a nuclear power reactor will
be issued unless a finding is made by the NRC that there is reasonable assurance that
adequate protective measures can and will be taken in the event of a radiological emergency.
Section 50.47 establishes standards onsite and offsite emergency response plans must meet
for the NRC staff to make a positive finding that there is reasonable assurance that adequate
protective measures can and will be taken in the event of a radiological emergency. One of
these standards, 10 CFR 50.47(b)(4), stipulates that Emergency Plans include a standard
emergency classification and action level scheme.
-2-
Section IV.B to Appendix E, Emergency Planning and Preparedness for Production and
Utilization Facilities, of 10 CFR Part 50 provides that Emergency Plans include EALs,
which are to be used as criteria for determining the need for notification and participation of
local and State agencies, and for determining when and what type of protective measures
should be considered to protect the health and safety of individuals both onsite and offsite.
EALs are to be based on plant conditions and instrumentation, as well as onsite and offsite
radiological monitoring. Section IV.B of Appendix E provides that initial EALs shall be
discussed and agreed on by the applicant and State and local authorities, be approved by the
NRC, and reviewed annually thereafter with State and local authorities. Therefore, a revision
will require NRC approval prior to implementation if it involves: (1) changing from one EAL
scheme to another, such as from an EAL scheme based on NUREG-0654/FEMA-REP-1 to one
based on NUMARC/NESP-007 or NEI 99-01; (2) the licensee proposing an alternate method
for complying with the regulations; or (3) the EAL revision proposed by the licensee decreases
the effectiveness of the Emergency Plan.
2.2 Guidance
Revision 4 to RG 1.101 endorses the guidance contained in NEI 99-01, Revision 4, and is
acceptable to the NRC staff as an alternative method to that described in the following
guidance for developing EALs required in Section IV.B to Appendix E of 10 CFR Part 50 and
Appendix 1 to NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of
Radiological Emergency Response Plans and Preparedness in Support of Nuclear
Power Plants (November 1980)
Nuclear Utilities Management Council (NUMARC) document, entitled NESP-007,
Methodology for Development of Emergency Action Levels (Revision 2,
January 1992).
Regulatory Issue Summary (RIS) 2003-18, Use of NEI 99-01, Methodology for Development of
Emergency Action Levels, dated October 8, 2003, provides guidance for developing or
changing a standard emergency classification and action level scheme. In addition,
RIS 2003-18 provides recommendations to assist licensees, consistent with Section IV.B to
Appendix E of Part 50, in determining whether to seek prior NRC approval of deviations from
the new guidance. Supplement 1 to RIS 2003-18, dated July 13, 2004, was issued to clarify
various technical positions regarding EAL revisions.
3.0 TECHNICAL EVALUATION
3.1 Scope
The proposed revision updates the existing DAEC NUMARC/NESP-007-based EALs to
implement the shutdown EALs and includes lessons-learned from NEI 99-01.
The NRC staffs evaluation of the proposed revisions to initiating conditions (ICs) and EAL
threshold values is based on information provided in Reference 1, as supplemented by
Reference 3. The NRC staff did not review EALs, including equipment and setpoints,
previously approved under the licensees existing NUMARC/NESP-007 EAL scheme which
-3-
were not revised under References 1 and 3. In addition, ICs entitled Defueled Station
Malfunctions, and listed under Category D in NEI 99-01, are not applicable since DAEC has a
current operating license, and therefore, were not considered during this technical evaluation.
Proposed deviations or differences, other than minor differences such as station-specific
terminology, system and component names, or formatting, from the guidance in NEI 99-01
were identified in the justification matrix provided in Enclosure 5 to Reference 3, which provided
a specific evaluation for each.
A complete revised version of the EAL Bases document, including EAL Matrix, ICs, and
associated EAL threshold values, was provided in Enclosure 4 to Reference 3. This EAL Bases
document reflected changes made to the EAL Matrix, ICs, EAL threshold values, and Bases
provided by Reference 1, and as supplemented by Reference 3.
3.2 Approval by State and Local Authorities
As stated in Section 2.1,Section IV.B of Appendix E to 10 CFR Part 50 states that initial EALs
shall be discussed and agreed on by the applicant and State and local authorities, be approved
by the NRC, and reviewed annually thereafter with State and local authorities.
The licensee states in Reference 3 that the proposed EALs had been discussed and agreed to
by the applicable State and local government officials. Enclosure 3 to Reference 3 contains
documentation of these discussions with the following offsite agencies:
Iowa Department of Public Health
Iowa Homeland Security & Emergency Preparedness Division
Linn County Emergency Management Agency
Benton County Emergency Management Agency
3.3 List of Commitments
Reference 3 contains no new commitments, and withdraws the commitment made in
Reference 1 to provide the NRC a supplemental submittal for the DAEC security EALs. The
licensee states in Reference 3 that NMC will not provide a supplement to reflect updated
security EALs for DAEC. Instead, NMC will evaluate revised DAEC security EALs in
accordance with 10 CFR 50.54(q) and will provide an additional submittal only if required.
3.4 Evaluation
Based on the review of the information provided in the licensees application submittal
(Reference 1), as supplemented by Reference 3, the NRC staff finds that the proposed
changes to DAEC ICs, EAL threshold values, and EAL Bases are consistent with the guidance
of NEI 99-01 or provide an acceptable alternative.
The proposed changes to the DAEC EALs, as reflected in Reference 3, are acceptable.
Changes to the DAEC security EALs, based on the guidance provided in Attachment 1 to
-4-
NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based
Events, dated July 18, 2005, were not evaluated as part of this review. As indicated in
Section 3.3 above, the licensee intends to implement changes to its security EALs under
10 CFR 50.54(q), which is acceptable under the guidance provided in Bulletin 2005-02.
4.0 CONCLUSIONS
The NRC staff has performed a review of the proposed changes to the DAEC EALs and EAL
Bases, as submitted in Reference 1, and as supplemented by Reference 3, using the guidance
in NEI 99-01, Revision 4. The NRC staff finds that the proposed DAEC EAL revisions are
consistent with the guidance in NEI 99-01 or provide an acceptable alternative as discussed in
this safety evaluation.
The NRC staff also finds that the EAL changes meet the standards of 10 CFR 50.47(b) and the
requirements of Appendix E of 10 CFR Part 50. The NRC staff concludes, based on the
considerations discussed above, that: (1) there is reasonable assurance that the health and
safety of the public will not be endangered by operation in the proposed manner, (2) such
activities will be conducted in compliance with the Commissions regulations, and (3) the
approval of the proposed Emergency Plan changes will not be inimical to the common defense
and security or to the health and safety of the public.
5.0 REFERENCES
1.
Peifer, M. A., Nuclear Management Company, LLC, to Document Control Desk, U.S.
Nuclear Regulatory Commission, Revision to Emergency Action Levels for the Duane
Arnold Energy Center Based on NEI 99-01, Methodology for Development of
Emergency Action Levels, Revision 4, October 22, 2004. ADAMS Accession No.
2.
Padovan, L. M., U.S. Nuclear Regulatory Commission, to Edward J. Weinkam, Nuclear
Management Company, LLC, Duane Arnold Energy Center, Kewaunee Nuclear Power
Plant, Monticello Nuclear Generating Plant, Palisades Nuclear Plant, Prairie Island
Nuclear Generating Plant, Units 1 and 2 - Request for Additional Information Regarding
Revisions to Emergency Action Levels, June 3, 2005. ADAMS Accession No.
3.
Van Middlesworth, G. D., Nuclear Management Company, LLC, to Document Control
Desk, U.S. Nuclear Regulatory Commission, Proposed Emergency Plan Changes
Related to Duane Arnold Energy Center Emergency Action Levels and Response to
Request for Additional Information, June 24, 2005. ADAMS Accession No.
Principal Contributor: J. Anderson
Date: October 18, 2005
Duane Arnold Energy Center
cc:
Mr. John Paul Cowan
Executive Vice President &
Chief Nuclear Officer
Nuclear Management Company, LLC
700 First Street
Hudson, MI 54016
John Bjorseth
Plant Manager
Duane Arnold Energy Center
3277 DAEC Road
Palo, IA 52324
Steven R. Catron
Manager, Regulatory Affairs
Duane Arnold Energy Center
3277 DAEC Road
Palo, IA 52324
U. S. Nuclear Regulatory Commission
Resident Inspectors Office
Rural Route #1
Palo, IA 52324
Regional Administrator
U. S. NRC, Region III
801 Warrenville Road
Lisle, IL 60532-4531
Jonathan Rogoff
Vice President, Counsel & Secretary
Nuclear Management Company, LLC
700 First Street
Hudson, WI 54016
Bruce Lacy
Nuclear Asset Manager
Alliant Energy/Interstate Power
and Light Company
3277 DAEC Road
Palo, IA 52324
Daniel McGhee
Utilities Division
Iowa Department of Commerce
Lucas Office Buildings, 5th floor
Des Moines, IA 50319
Chairman, Linn County
Board of Supervisors
930 1st Street SW
Cedar Rapids, IA 52404
Craig G. Anderson
Senior Vice President, Group Operations
700 First Street
Hudson, WI 54016