ML071430517

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Emergency Preparedness Dose Projection Method Changes (TAC Nos. MD4821 and MD4822)
ML071430517
Person / Time
Site: Beaver Valley
Issue date: 05/24/2007
From: Nadiyah Morgan
NRC/NRR/ADRO/DORL/LPLI-1
To: Lash J
FirstEnergy Nuclear Operating Co
Morgan N, NRR/DORL, 415-3650
References
TAC MD4821, TAC MD4822
Download: ML071430517 (7)
v • d • e


Text

May 24, 2007 Mr. James H. Lash Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - EMERGENCY PREPAREDNESS DOSE PROJECTION METHOD CHANGES (TAC NOS.

MD4821 AND MD4822)

Dear Mr. Lash:

By letter dated January 11, 2007, FirstEnergy Nuclear Operating Company (FENOC, licensee) committed to submitting proposed changes to the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 & 2) Emergency Plan Implementing Procedures. Specifically, the proposed changes would change the default dose projection release duration from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for situations when a radiation release duration cannot be reasonably estimated or determined. By letter dated January 31, 2007, as supplemented by letter dated April 12, 2007, the licensee submitted the proposed changes and requested Nuclear Regulatory Commission (NRC) approval.

The NRC staff concluded that incorporation of the proposed changes does not decrease the effectiveness of the Emergency Plan Implementing Procedures or the Emergency Plan, and the plan, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to Part 50 to Title 10 of the Code of Federal Regulations. A copy of the related safety evaluation is enclosed.

Please contact me at (301) 415-1016, if you have any questions on this issue.

Sincerely,

/RA/

Nadiyah S. Morgan, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

As stated cc w/encl: See next page

ML071430517 *See memo dated May 11, 2007 OFFICE LPLI-1/PM LPLI-1/LA NSIR/DPR/BC LPLI-1/BC NAME NMorgan SLittle Weiss* MKowal DATE 5/24/07 5/24/07 5/11/2007 5/24/07 Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Joseph J. Hagan P.O. Box 4, Route 168 Senior Vice President of Operations Shippingport, PA 15077 and Chief Operating Officer FirstEnergy Nuclear Operating Company Director, Fleet Regulatory Affairs Mail Stop A-GO-14 FirstEnergy Nuclear Operating Company 76 South Main Street Mail Stop A-GO-2 Akron, OH 44308 76 South Main Street Akron, Ohio 44333 James H. Lash Senior Vice President of Operations Manager, Site Regulatory Compliance and Chief Operating Officer FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-GO-14 Mail Stop A-BV-A 76 South Main Street P.O. Box 4, Route 168 Akron, OH 44308 Shippingport, PA 15077 Danny L. Pace Richard Anderson Senior Vice President, Fleet Engineering Vice President, Nuclear Support FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Mail Stop A-GO-14 76 South Main Street Akron, Ohio 44308 Akron, OH 44308 Commissioner James R. Lewis Jeannie M. Rinckel West Virginia Division of Labor Vice President, Fleet Oversight 749-B, Building No. 6 FirstEnergy Nuclear Operating Company Capitol Complex Mail Stop A-GO-14 Charleston, WV 25305 76 South Main Street Akron, OH 44308 Director, Utilities Department Public Utilities Commission David W. Jenkins, Attorney 180 East Broad Street FirstEnergy Corporation Columbus, OH 43266-0573 Mail Stop A-GO-18 76 South Main Street Director, Pennsylvania Emergency Akron, OH 44308 Management Agency 2605 Interstate Dr.

Manager, Fleet Licensing Harrisburg, PA 17110-9364 FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44333 Ohio EPA-DERR ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149 Pete Sena Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1

Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO PROPOSED EMERGENCY PREPAREDNESS CHANGES FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412

1.0 INTRODUCTION

By letter dated January 11, 2007, Agencywide Documents Access and Management System (ADAMS) Accession No. ML070160236, FirstEnergy Nuclear Operating Company (FENOC, licensee) committed to submitting proposed changes to the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 & 2) Emergency Plan Implementing Procedures (EPIPs). Specifically, the proposed changes would change the default dose projection release duration from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for situations when a radiation release duration cannot be reasonably estimated or determined. By letter dated January 31, 2007, ADAMS Accession No. ML070330547, as supplemented by letter dated April 12, 2007, ADAMS Accession No. ML071030383, the licensee submitted the proposed changes and requested the Nuclear Regulatory Commission (NRC) approval.

2.0 REGULATORY EVALUATION

The applicable regulations and guidance that the licensee must meet for the emergency plans are as follows:

2.1 Regulations The underlying purpose of the standards in Section 47(b) of Part 50 to 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:

  • 10 CFR 50.47(b)(9) states, Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
  • 10 CFR 50.47(b)(10) states, A range of protective actions has been developed for the plume exposure pathway EPZ [emergency planning zone] for emergency workers and the public. In developing this range of protective actions, consideration has been given to evacuation, sheltering, and as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
  • Appendix E to 10 CFR Part 50, Section IV.B, in part, states, The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring.

2.2 Guidance

  • NUREG-0654/FEMA Rep-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980, provides guidance to licensees in the development of their emergency plans.

3.0 TECHNICAL EVALUATION

The proposed changes to the EPIPs would change the default dose projection release duration from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for situations when a radiation release duration cannot be reasonably estimated or determined. The NRC staff reviewed the documentation provided and verified that the EPIPs have statements that direct their emergency response organization to make every attempt to quantify the projected release duration, and in situations where the radiation release duration cannot be reasonably estimated or determined, to assume a 6-hour release duration.

The 6-hour release was derived from Appendix B of the BVPS-1 and 2 Emergency Preparedness Plan, Demography and Evacuation Evaluation, which states that 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is the estimated time required to evacuate 90 percent of the EPZ population to outside of the EPZ during daytime hours with high vehicle demand and adverse weather conditions.

Increasing the default release duration from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is expected to minimize the likelihood of underestimating the offsite doses, with the potential for untimely and inaccurate protective action recommendations for protecting the health and safety of the general public, should there be a radiological release. Although the increased default release duration could result in overestimated offsite doses and unnecessary evacuations under certain conditions, the procedural requirement to make every attempt to quantify the projected release duration prior to

using the 6-hour default duration, is expected to minimize the likelihood of this outcome. As such, the NRC staff concludes that the proposed change in the default release duration will not decrease the effectiveness of the BVPS-1 and 2 Emergency Plan.

4.0 CONCLUSION

The NRC staff performed a technical and regulatory review of the proposed changes to the EPIPs. 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 of the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the proposed changes will not be inimical to the common defense and security or to the health and safety of the public.

5.0 REFERENCES

1. BVPS Letter L-07-021, Proposed Changes to Emergency Preparedness Dose Projection Methods, dated January 31, 2007. (ADAMS Accession No. ML070330547)
2. BVPS Letter L-07-063, Supplement to Proposed Changes to Emergency Preparedness Dose Projection Methods, dated April 12, 2007. (ADAMS Accession No. ML071030383)
3. NUREG-0654/FEMA Rep-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980. (ADAMS Accession No. ML040420012)
4. NRC Regulatory Issue Summary 2005-02, Clarifying the Process for Making Emergency Plan Changes dated February 14, 2005. (ADAMS Accession No. ML042580404)

Principal Contributor: D. Johnson Date: May 24, 2007

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