ML070320124
| ML070320124 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/08/2007 |
| From: | Gratton C NRC/NRR/ADRO/DORL/LPLIII-2 |
| To: | Crane C Exelon Generation Co |
| Gratton C, NRR, DORL, 415-1055 | |
| References | |
| TAC LS2697, TAC MD2862 | |
| Download: ML070320124 (9) | |
Text
February 8, 2007 Christopher M. Crane President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
THREE MILE ISLAND NUCLEAR STATION, UNITS 1 AND 2 - REVISION OF EMERGENCY ACTION LEVELS IN RADIOLOGICAL EMERGENCY RESPONSE PLAN (TAC NOS. MD2862 AND LS2697)
Dear Mr. Crane:
By letter dated August 15, 2006, and supplemented by letters dated December 1, and December 14, 2006, Exelon Generation Company, LLC, and AmerGen Energy Company, LLC, (Exelon/AmerGen), requested prior Nuclear Regulatory Commission (NRC) approval for changes to the emergency action levels (EALs) for the following stations: Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Station, Units 1 and 2; and Three Mile Island Nuclear Station, Units 1 and 2 (TMI).
Subsequent to Exelon/AmerGens December 1, 2006, supplement, Exelon/AmerGen informed the staff during a teleconference on December 13, 2006, that they intend to supplement the EAL submittal for TMI. Exelon/AmerGen followed that notification with an e-mail on December 14, 2006, reiterating their intent to supplement the TMI submittal. As a result, the NRC staff completed its review of the proposed changes for all plants except TMI, and documented the results of the review in a letter dated January 17, 2007.
The changes to the EALs support a conversion from an EAL scheme currently based on NUMARC/NESP-007, Revision 2, Methodology for Development of Emergency Action Levels to a scheme based on NEI 99-01, Methodology for Development of Emergency Action Levels (Revision 4, January 2003), in accordance with Regulatory Issue Summary 2003-18, with Supplements 1 and 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels.
As discussed in the enclosed safety evaluation, the Commission concludes that the EAL changes proposed herein meet the standards of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.47(b) and the requirements of Section IV.B of Appendix E to 10 CFR Part 50, and are, therefore, acceptable.
Sincerely,
/RA/
Christopher Gratton, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-289 and 50-320
Enclosure:
Safety Evaluation cc w/encl: See next page
ML070320124 NRR-106 OFFICE NRR/LPL3-2/PM NRR/LPL3-2/LA NSIR/LRB NSIR/LRB/BC NRR/LPL3-2/BC NAME CGratton EWhitt DJohnson EWeiss MMarshall DATE 2/2/07 2/2/07 2/2/07 2/2/07 2/8/07
Three Mile Island Nuclear Station, Unit 1 cc:
Site Vice President - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057 Senior Vice President - Nuclear Services AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations, Mid-Atlantic AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regional Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Chairman Board of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120 Chairman Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 Senior Resident Inspector (TMI-1)
U.S. Nuclear Regulatory Commission P.O. Box 219 Middletown, PA 17057 Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Plant Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057 Regulatory Assurance Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P.O. Box 480 Middletown, PA 17057 Ronald Bellamy, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Michael A. Schoppman Framatome ANP Suite 705 1911 North Ft. Myer Drive Rosslyn, VA 22209 Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101
Three Mile Island Nuclear Station, Unit 1 cc:
Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 Correspondence Control Desk AmerGen Energy Company, LLC P.O. Box 160 Kennett Square, PA 19348 Manager Licensing - Three Mile Island Nuclear Station, Unit 1 Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Assistant General Counsel AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO A PROPOSED REVISION TO THE EMERGENCY ACTION LEVELS THREE MILE ISLAND GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-289 AND 50-320
1.0 INTRODUCTION
By letter dated August 15, 2006 (Reference No. 1), supplemented by letters dated December 1, 2006 (Reference No. 2), and December 14, 2006 (Reference No. 3), Exelon Generation Company, LLC, and AmerGen Energy Company, LLC, (Exelon/AmerGen) requested prior Nuclear Regulatory Commission (NRC) approval for changes to the emergency action levels (EALs) for the following stations: Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Station, Units 1 and 2; and Three Mile Island Nuclear Station, Units 1 and 2 (TMI).
Subsequent to Exelon/AmerGens December 1, 2006, supplemental response, Exelon/AmerGen informed the NRC staff during a teleconference on December 13, 2006, that they intended to supplement the TMI submittal. Exelon/AmerGen followed that notification with an e-mail (Reference No. 8) on December 14, 2006, reiterating their intent to supplement the TMI submittal.
The requested changes to the licensees EALs supports a conversion from an EAL scheme currently based on NUMARC/NESP-007, Revision 2, Methodology for Development of Emergency Action Levels (Reference No. 4), to a scheme based on NEI 99-01, Methodology for Development of Emergency Action Levels (Revision 4, January 2003) (Reference No. 5), in accordance with Regulatory Issue Summary (RIS) 2003-18, with Supplements 1 and 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels (Reference No. 6).
These changes have been evaluated by Exelon/AmerGen to be an alternate method for complying with the regulations and have been submitted to the NRC for prior approval.
2.0 REGULATORY EVALUATION
The NRC staff reviewed the proposed revision against the following regulations and guidance:
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, in part, that no operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that the state of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Section 50.47 also establishes standards that must be met by the onsite and offsite emergency response plans for 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, 50.47(b)(4), stipulates that emergency plans include a standard emergency classification and action level scheme.
Section IV.B to Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, of 10 CFR Part 50 provides that emergency plans are to include EALs, which are to be used as criteria for determining the need for notification and participation of State and local agencies, and which are to be used for determining when and what type of protective measures should be considered both onsite and offsite to protect health and safety.
EALs are to be based on in-plant conditions and instrumentation, and also on onsite and offsite 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, and be approved by NRC, and reviewed annually thereafter with State and local authorities. In addition,Section IV.B of Appendix E states, in part, that an EAL revision must be approved by the NRC before implementation if it involves: (1) the changing from an EAL scheme based on NUREG-0654/FEMA-REP-1 to a scheme based on NUMARC/NESP-007 or NEI 99-01; (2) the licensee is proposing an alternate method for complying with the regulations; or (3) the EAL revision has been evaluated by licensee as constituting a decrease in effectiveness.
2.2 Guidance Revision 4 to Regulatory Guide (RG) 1.101 (Reference No. 7), issued in July 2003, endorses the guidance contained in Reference No. 5 as acceptable to the NRC staff as an alternative method to that described in the following guidance for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4):
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), and Nuclear Utilities Management Council (NUMARC) document, entitled NESP-007, Methodology for Development of Emergency Action Levels (Revision 2, January 1992).
Reference No. 6 provides guidance for developing or changing a standard emergency classification and action level scheme. In addition, this provided 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.
3.0 TECHNICAL EVALUATION
Since the proposed revision to the Exelon/AmerGen EALs were evaluated by Exelon/AmerGen to be an alternate method for complying with the regulations, the proposed changes were submitted to the NRC for approval prior to implementation by the licensee.
The licensees currently utilize an EAL scheme based on Reference No. 4. The licensees are converting to an EAL scheme based on Reference No. 5 in accordance with the guidance from Reference No. 6.
The NRC staff has reviewed the application (Reference No. 1), responses to NRC RAIs (Reference No. 2), and the TMI supplement (Reference No. 10). The NRC staff reviewed the proposed EALs against the guidance in Reference No. 5 to determine if the EALs, as proposed, meet the following guidelines:
(1) Consistency, (i.e., the EALs would lead to similar decisions under similar circumstances at different plants);
(2) Human engineering and user friendliness; (3) Potential for classification upgrade only when there is an increasing threat to public health and safety; (4) Ease of upgrading and downgrading; (5) Thoroughness in addressing, and disposing of, the issues of completeness and accuracy raised regarding NUREG-0654 Appendix 1; (6) Technical completeness for each classification level; (7) A logical progression in classification for multiple events; and (8) Objective, observable values.
The NRC staff reviewed the proposed EALs against EALs implemented at other plants of a similar design and has determined that the proposed EALs are consistent with EALs implemented at other plants, uses objective and observable values, and is consistent with the intent of Reference No. 5.
The NRC staff has determined that the proposed EALs are worded such that human engineering and user friendliness concerns are addressed.
The NRC staff reviewed the proposed EAL sets, (a group of EALs within a category related to a common concern, i.e., the Unusual Event, Alert, Site Area Emergency, and General Emergency related to a failure of the plant to shutdown via an automatic scram would be considered an EAL set), and has determined that classification upgrades are based upon an increasing threat to public health and safety, can effectively support upgrading and downgrading, follows a logical progression for multiple events, and is in accordance with the intent of Reference No. 5.
The NRC staff reviewed the proposed EALs for technical completeness and accuracy and has determined that the proposed EALs are consistent with Reference No. 5 which was determined to be an acceptable alternative to NUREG-0654 Appendix 1 EALs (Reference No. 7).
4.0 CONCLUSION
The NRC staff performed a review of the proposed changes to the Exelon/AmerGen EALs described in Reference No. 1, as supplemented by References Nos. 2 and 10, and determined them to be consistent with the guidance of Reference No. 5. As such, the proposed EAL changes meet the requirements of 10 CFR 50.47(b) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the following is acceptable:
Three Mile Island Generating Station, Units 1 and 2: Attachment 3 to Reference No. 10 (ADAMS Accession No. ML063430106).
5.0 REFERENCES
1.
Letter Number RS-06-114 from Exelon/AmerGen to the NRC dated August 15, 2006, Exelon/AmerGen Implementation of Emergency Action Levels Developed from NEI 99-01. ADAMS Accession No. ML062790096.
2.
Letter Number RS-06-170 from Exelon/AmerGen to the NRC dated December 1, 2006, Exelon/AmerGen Response to Request for Additional Information for Implementation of Emergency Action Levels Developed from NEI 99-01. ADAMS Accession No. ML063450456.
3.
Letter Number 2130-06-20439 from Exelon/AmerGen to the NRC dated December 14, 2006, Exelon/AmerGen Supplement to Submittal to Revise Oyster Creek Emergency Action Levels Developed from NEI 99-01. ADAMS Accession No. ML063540086.
4.
Nuclear Utilities Management Council (NUMARC) document, entitled NESP-007, Methodology for Development of Emergency Action Levels (Revision 2, January 1992). ADAMS Accession No. ML041120174.
5.
NEI 99-01 Methodology for Development of Emergency Action Levels (Revision 4, January 2003). ADAMS Accession No. ML041470143.
6.
Regulatory Issue Summary 2003-18, with Supplements 1 and 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels. ADAMS Accession Nos.
ML032580518, ML041550395, and ML051450482.
7.
Regulatory Guide 1.101, Revision 4, Emergency Planning and Preparedness for Nuclear Power Reactors. ADAMS Accession No. ML032020276.
8.
December 14, 2006, email informing NRC Staff of Exelon/AmerGens decision to supplement the submittal for TMI at a later date. ADAMS Accession No. ML070120274.
9.
Safety Evaluation dated January 17, 2007, Braidwood Station, Units 1 and 2; Byron Station, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and Three Mile Island Nuclear Station, Units 1 and 2 - Revision of Emergency Action Levels in Radiological Emergency Response Plan. ADAMS Accession No. 070120260.
10.
Letter Number 5928-07-20263 from Exelon/AmerGen dated January 12, 2007, Exelon/AmerGen Supplement of TMIs Submittal to Revise Emergency Action Levels Developed from NEI 99-01. ADAMS Accession No. ML070160638.
Principal Contributor: D. Johnson, NSIR Date: February 8, 2007