ML071100068
| ML071100068 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 04/30/2007 |
| From: | Martin R NRC/NRR/ADRO/DORL/LPLII-1 |
| To: | Gasser J Southern Nuclear Operating Co |
| Martin R, NRR/DORL, 415-1493 | |
| References | |
| TAC MC9457, TAC MC9458, TAC MC9459, TAC MC9460, TAC MC9461, TAC MC9462 | |
| Download: ML071100068 (11) | |
Text
April 30, 2007 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham, AL 35201-1295
SUBJECT:
EMERGENCY ACTION LEVEL REVISIONS FOR SOUTHERN NUCLEAR OPERATING COMPANY, INC., EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 (HNP); JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (FNP); VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 (VEGP)
(TAC NOS. MC9459, MC9460, MC9457, MC9458, MC9461, AND MC9462)
Dear Mr. Gasser:
By letter dated December 30, 2005, as supplemented by letters dated October 13, 2006, and April 2, 2007, Southern Nuclear Operating Company, Inc., requested prior Nuclear Regulatory Commission (NRC) approval for changes to the emergency action levels (EALs) for HNP, FNP, and the VEGP.
The requested changes to the licensees EALs support a conversion from their current EAL scheme to a scheme based on Nuclear Emergy Institutes (NEIs) 99-01, Methodology for Development of Emergency Action Levels, Revision 4, January 2003, in accordance with Regulatory Issue Summary 2003-18, including Supplements 1 and 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels. HNP and FNP currently use an EAL scheme based on NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. VEGP currently uses an EAL scheme based on NUMARC (Nuclear Management and Resources Counsel (now NEI)/NESP (National Environmental Studies Project) NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, Revision 2.
The NRC staff has completed a technical and regulatory review of the proposed EAL changes and supporting documentation. We have concluded that incorporation of the proposed changes do not decrease the effectiveness of the applicable Emergency Plans and that the plans, as changed, continue to meet the standards of Title 10 of the Code of Federal Regulations, Part 50, Section 50.47, Emergency plans, paragraph (b) and the requirements of Appendix E to Part 50, Emergency Planning and Preparedness for Production
J. Gasser and Utilization Facilities. The basis for our conclusion is contained in the enclosed safety evaluation. If you have any questions, please contact me at 301-415-1493.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321, 50-366, 50-348, 50-364, 50-424, and 50-425
Enclosure:
Safety Evaluation cc w/encl: See next page
J. Gasser April 30, 2007 and Utilization Facilities. The basis for our conclusion is contained in the enclosed safety evaluation. If you have any questions, please contact me at 301-415-1493.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321, 50-366, 50-348, 50-364, 50-424, and 50-425
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
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RidsAcrsAcnwMailCenter RidsOgcRp EWeiss, NSIR DJohnson, NSIR Accession Number: ML071100068
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- EMarinos DATE 4/30/2007 4/30/2007 04/18/2007 4/30/2007 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO PROPOSED REVISIONS TO THE EMERGENCY ACTION LEVELS FOR THE EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 (HNP)
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (FNP)
VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 (VEGP)
DOCKET NOS. 50-321, 50-366, 50-348, 50-364, 50-424, AND 50-425
1.0 INTRODUCTION
By letter dated December 30, 2005 (Reference No. 1), as supplemented by letters dated October 13, 2006 and April 2, 2007 (Reference Nos. 2 and No. 3), Southern Nuclear Operating Company, Inc. (SNC or licensee), requested prior Nuclear Regulatory Commission (NRC) staff approval for changes to the emergency action levels (EALs) for HNP, FNP, and VEGP.
The requested changes to the licensees EALs support a conversion from their current EAL scheme to a scheme based on Nuclear Emergy Institutes (NEIs) 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, including Supplements 1 & 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, (Reference No. 6).
HNP and FNP currently use an EAL scheme based on NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (Reference No. 8). VEGP currently uses an EAL scheme based on NUMARC (Nuclear Management and Resources Counsel (now NEI)/NESP (National Environmental Studies Project) NUMARC NUMARC/NESP-007, Revision 2 Methodology for Development of Emergency Action Levels, (Reference No. 4).
2.0 REGULATORY EVALUATION
2.1 Regulations Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.47, Emergency plans, paragraph (a)(1), states 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, Assessment Actions, 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 local and State 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 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 (Federal Emergency Management Agency), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980, 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 the licensee as constituting a decrease in effectiveness.
2.2 Guidance Revision 4 to Regulatory Guide (RG) 1.101, issued in July 2003 (Reference No. 7), 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):
1.
Appendix 1 to NUREG-0654 2.
NUMARC/NESP-007, Revision 2 Reference No. 6 provides guidance for developing or changing a standard emergency classification and action level scheme. In addition, this RIS 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 guidance.
3.0 TECHNICAL EVALUATION
The proposed changes were submitted to the NRC for a technical and regulatory review prior to implementation by the licensee, as required under Section IV.B of Appendix E to 10 CFR Part 50.
This evaluation is based on a revision to EALs provided in the application letter and supplemented by SNCs response to the NRCs requests for additional information.
FNP and HNP currently utilize an EAL scheme based on Reference No. 8. VEGP currently utilizes 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 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 staff has determined that the proposed EALs are worded such that human engineering and user friendliness concerns are addressed.
The 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 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 technical and regulatory review of the proposed changes to the HNP, FNP, and VEGP EALs. The NRC 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 proposed emergency plan changes will not be inimical to the common defense and security or to the health and safety of the public. The NRC staff has determined that incorporation of the proposed changes do not decrease the effectiveness of the applicable Emergency Plans and the plans, as changed, continue to meet the standards of Section 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
Reference No. 9 contains the EAL Basis Documents for FNP, HNP, and VEGP.
5.0 REFERENCES
1.
Letter from Southern Nuclear Operating Company, Inc., to the NRC dated December 30, 2005, Transition to NEI 99-01 Emergency Action Level Scheme, Agencywide Documents Access Management Systems (ADAMS) Accession No. ML060180178.
2.
Letter from Southern Nuclear Operating Company, Inc., to the NRC dated October 13, 2006, Response to Request for Additional Information, ADAMS Accession No. ML063120370.
3.
Letter from Southern Nuclear Operating Company, Inc., to the NRC dated April 2, 2007, Response to Request for Additional Information, ADAMS Accession No. ML071010377.
4.
NUMARC (Nuclear Utilities Management Counsel (now NEI)/NESP (National Environmental Studies Project) 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, including Supplements 1 and 2, Use of NEI 99-01, Methodology for Development of Emergency Action Levels,. ADAMS Accession Nos.
ML032580518, ML041550395, and ML051450482.
7.
Emergency Planning and Preparedness for Nuclear Power Reactors, RG 1.101, Revision 4, July 2003, ADAMS Accession No. ML032020276.
8.
NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, ADAMS Accession No. ML040420012.
9.
Technical Basis for FNP, HNP and VEGP, as referenced in Enclosure 2 of reference 3, ADAMS No. ML071010426.
Principal Contributor: Don A. Johnson, NSIR/DPR Date: April 30, 2007
Joseph M. Farley Nuclear Plant, Units 1 & 2 cc:
Mr. J. Randy Johnson Vice President - Farley Joseph M. Farley Nuclear Plant 7388 North State Highway 95 Columbia, AL 36319 Mr. B. D. McKinney, Licensing Manager Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm P.O. Box 306 1710 Sixth Avenue North Birmingham, AL 35201 Mr. J. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201 State Health Officer Alabama Department of Public Health 434 Monroe St.
Montgomery, AL 36130-1701 Chairman Houston County Commission P.O. Box 6406 Dothan, AL 36302 Resident Inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, AL 36319 William D. Oldfield SAER Supervisor Southern Nuclear Operating Company, Inc.
P.O. Box 470
Ashford, AL 36312 Edwin I. Hatch Nuclear Plant, Units 1 & 2 cc:
Mr. Dennis R. Madison Vice President - Hatch Edwin I. Hatch Nuclear 11028 Hatch Parkway North Baxley, GA 31513 Laurence Bergen Oglethorpe Power Corporation 2100 E. Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Mr. R. D. Baker Manager - Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Resident Inspector Plant Hatch 11030 Hatch Parkway N.
Baxley, GA 31531 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, GA 30334 Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Arthur H. Domby, Esq.
Troutman Sanders Nations Bank Plaza 600 Peachtree St, NE, Suite 5200 Atlanta, GA 30308-2216 Chairman Appling County Commissioners County Courthouse Baxley, GA 31513 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. K. Rosanski Resident Manager Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant P.O. Box 2010 Baxley, GA 31515
Vogtle Electric Generating Plant, Units 1 & 2 cc:
Mr. Tom E. Tynan Vice President - Vogtle Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830 Mr. N. J. Stringfellow Manager, Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Mr. Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 Mr. Laurence Bergen Oglethorpe Power Corporation 2100 East Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Arthur H. Domby, Esquire Troutman Sanders Nations Bank Plaza 600 Peachtree Street, NE Suite 5200 Atlanta, GA 30308-2216 Resident Inspector Vogtle Plant 8805 River Road Waynesboro, GA 30830 Office of the County Commissioner Burke County Commission Waynesboro, GA 30830