ML063400271
| ML063400271 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/06/2006 |
| From: | Kalyanam N NRC/NRR/ADRO/DORL/LPLIV |
| To: | Rosenblum R Southern California Edison Co |
| Kalyanam N, NRR/DORL, 415-1480 | |
| References | |
| TAC MD3671, TAC MD3672 | |
| Download: ML063400271 (7) | |
Text
December 6, 2006 Mr. Richard M. Rosenblum Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION -
PROPOSED EMERGENCY PLAN CHANGES TO REVISE THE PROTECTIVE ACTION RECOMMENDATION METHODOLOGY (TAC NOS. MD3671 AND MD3672)
Dear Mr. Rosenblum:
By application letter dated November 17, 2006, Southern California Edison (SCE) requested prior approval for changes to the San Onofre Nuclear Generating Station (SONGS) Emergency Plan (E-Plan).
The proposed changes would revise the Protective Action Recommendation (PAR) methodology for the SONGS E-Plan. The current SONGS PAR methodology requires an evacuation or sheltering PAR for the entire emergency planning zone (EPZ) when a general emergency has been declared. The proposed SONGS PAR methodology would segment the EPZ into several protective action zones and would allow for a more risk-informed PAR decision that takes wind-direction, release duration, impediments to evacuation, and radiological consequences into consideration.
R. Rosenblum The Nuclear Regulatory Commission staff has completed its review of the proposed E-Plan changes and supporting documentation, and has concluded that the proposed changes meet the standards of Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.47(b) and the requirements of Appendix E to 10 CFR Part 50 and, therefore, are considered acceptable.
A copy of our related Safety Evaluation is also enclosed.
Sincerely,
/RA/
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-206, 50-361, 50-362, and 72-41
Enclosure:
Safety Evaluation cc w/encl: See next page
R. Rosenblum The Nuclear Regulatory Commission staff has completed its review of the proposed E-Plan changes and supporting documentation, and has concluded that the proposed changes meet the standards of Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.47(b) and the requirements of Appendix E to 10 CFR Part 50 and, therefore, are considered acceptable.
A copy of our related Safety Evaluation is also enclosed.
Sincerely,
/RA/
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-206, 50-361, 50-362, and 72-41
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION PUBLIC LPLIV r/f RidsNrrDorl (CHaney/JLubinski)
RidsNrrDorlLpl4 (DTerao)
RidsNrrPMNKalyanam RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn4MailCenter DJohnson (NSIR/DPR)
MNorris (NSIR/DPR)
RidsNrrLALFeizollahi ACCESSION NO: ML063400271
- Minor editorial changes from staff provided SE OFFICE NRR/LPL4/PM NRR/LPL4/LA NSIR/DPR*
NRR/LPL4/BC NAME NKalyanam LFeizollahi EWeiss DTerao DATE 12-6-06 12//6/06 12/4/06 12/6/06 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NOS. 50-206, 50-361, 50-362, AND 72-41
1.0 INTRODUCTION
By application letter dated November 17, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML063330071 - Non-Publicly Available),
Southern California Edison (SCE, the licensee) requested prior approval for changes to the San Onofre Nuclear Generating Station (SONGS) Emergency Plan (E-Plan). The proposed changes would revise the Protective Action Recommendation (PAR) methodology for the SONGS E-Plan. The current SONGS PAR methodology requires an evacuation or sheltering PAR for the entire emergency planning zone (EPZ) when a general emergency (GE) has been declared.
The proposed SONGS PAR methodology would segment the EPZ into several protective action zones (PAZ) and would allow for a more risk-informed PAR decision that takes wind-direction, release duration, impediments to evacuation, and radiological consequences into consideration.
2.0 REGULATORY EVALUATION
The underlying purpose of the standards in paragragh 50.47(b) of Title 10 of the Code of Federal Regulations (10 CFR) is to ensure nuclear power reactor licensees have emergency response plans that provide reasonable assurance that adequate protective measures would be taken in the event of an emergency at a nuclear power reactor.
The following regulatory requirements are applicable:
Paragraph 50.47(b)(10) of 10 CFR requires, in part, that licensees develop a range of protective actions for the public in the plume exposure pathway EPZ. This regulation also requires that guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, be developed and in place.
Section III, The Final Safety Analysis Report, of Appendix E to 10 CFR Part 50 requires that plans for coping with emergencies contain information to provide assurance of coordination among the supporting groups and with the licensee. Therefore, changes to a licensees E-Plan related to protective actions should be coordinated with the offsite response organizations.
Nuclear Regulatory Commission (NRC) Regulatory Issue Summary (RIS) 2005-02, Clarifying the Process for Making Emergency Plan Changes, dated February 14, 2005, provides guidance to licensees making changes to their E-Plans.
NRC RIS 2005-08, Endorsement of Nuclear Energy Institute (NEI) Guidance <Range of Protective Actions for Nuclear Power Plant Incidents, dated June 6, 2005, provides endorsement of NEI guidance related to PARs.
3.0 TECHNICAL EVALUATION
Since the proposed revision to the SONGS E-Plan was evaluated by SCE to be an alternate method to meet Federal PAR regulations, the proposed changes were submitted to the NRC for approval prior to implementation by the licensee.
This evaluation is based on revisions to the applicable E-Plan provided in application letter dated November 17, 2006.
The NRC staff has reviewed SCEs technical and regulatory analysis in support of the proposed E-Plan changes.
The proposed PAR methodology provides a more risk-informed PAR to be developed by the licensee. The EPZ will be segmented into five separate PAZs. Evacuation and sheltering decisions will now take into account wind-direction, release duration, impediments to evacuation, and radiological consequences. The resultant PAR will therefore be restricted to those PAZs that are impacted based upon wind-direction and radiological consequences. The proposed PAR methodology is consistent with the guidance contained in RIS 2005-08 as well as maintaining alignment with the offsite jurisdictions and SONGS, thereby eliminating any need to convert a SONGS PAR into a different protective action decision by the offsite jurisdictions. This will have a positive impact on the timeliness of the protective action decision and, therefore, enhances the protection of the health and safety of the public. These changes are considered acceptable.
The proposed SONGS E-Plan change also requests prior approval to eliminate a PAR at the site area emergency (SAE) level that would require a PAR to shelter the entire EPZ if a dose value of 170 mRem total effective dose equivalent is measured or projected at the exclusion area boundary (EAB). A sheltering PAR is not required at the SAE level and is unrealistic in that the loss of two of three fission product barriers, with the loss or potential loss of the third barrier, would need to occur for this dose value to be projected or measured at the EAB. A loss of two of three fission product barriers, with the loss or potential loss of the third barrier, would necessitate a GE declaration with the resultant PAR based upon radiological consequences, impediments to evacuation, wind direction, and release duration. This change is considered acceptable.
The proposed SONGS E-Plan change also requests prior approval of a change to simplify the PAR decision to ingest potassium iodide (KI). The current E-Plan required a decision to ingest KI within the entire EPZ if a GE was declared with a radioactive release and an iodine source term. The proposed E-Plan would make the KI ingestion PAR a default action for the affected PAZ whenever a GE is declared. This change is considered acceptable.
Local offsite response organizational approval for these changes to the SONGS E-Plan has been obtained by the licensee as evidenced by a copy of the meeting minutes documenting unanimous approval for these changes. Also, by letter dated November 17, 2006, the Interjurisdictional Planning Committee (IPC) requested an expedited approval of the changes to the SONGS PAR methodology. The IPC is a multi-jurisdictional entity responsible for leading this coordinated effort to revise the PAR methodology for SONGS, including offsite emergency response plans, public education programs, Emergency Alert System messages, and interjurisdictional policies.
4.0 CONCLUSION
The staff performed a review of the proposed changes to the SONGS E-Plan. As such, the proposed E-Plan changes meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The staff has determined, 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.
The proposed changes to the SONGS E-Plan, as reflected in the submitted documentation, are acceptable.
Principal Contributor: Don Johnson Date: December 6, 2006
March 2006 San Onofre Nuclear Generating Station Units 2 and 3 cc:
Mr. Daniel P. Breig Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. Douglas K. Porter, Esquire Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 Mr. David Spath, Chief Division of Drinking Water and Environmental Management P.O. Box 942732 Sacramento, CA 94234-7320 Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Mr. Gary L. Nolff Assistant Director - Resources City of Riverside 3900 Main Street Riverside, CA 92522 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Michael R. Olson San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Director, Radiologic Health Branch State Department of Health Services P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Resident Inspector/San Onofre NPS c/o U.S. Nuclear Regulatory Commission Post Office Box 4329 San Clemente, CA 92674 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672 Mr. James T. Reilly Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 31)
Sacramento, CA 95814 Mr. Ray Waldo, Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92764-0128 Mr. Brian Katz Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92764-0128 Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899 Mr. A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128