ML071910442
| ML071910442 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/19/2007 |
| From: | Geoffrey Miller NRC/NRR/ADRO/DORL/LPLI-2 |
| To: | Peschel J, St.Pierre G Florida Power & Light Energy Seabrook |
| Miller G, NRR/DORL, 415-2481 | |
| References | |
| TAC MD3927 | |
| Download: ML071910442 (8) | |
Text
July 19, 2007 Mr. Gene F. St. Pierre, Site Vice President c/o James M. Peschel Seabrook Station FPL Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874
SUBJECT:
SEABROOK STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION (RAI), CONVERSION TO NEI 99-01, REVISION 4, EMERGENCY ACTION LEVEL BASIS (TAC NO. MD3927)
Dear Mr. St. Pierre:
By letter dated December 29, 2006, FPL Energy Seabrook, LLC, submitted a request for Nuclear Regulatory Commission (NRC) review and approval to implement the Emergency Action Levels contained in the Nuclear Energy Institute (NEI) document, NEI 99-01, Methodology for Development of Emergency Action Levels Scheme, for the Seabrook Station, Unit No. 1.
The NRC staff has been reviewing the submittal and has determined that additional information is needed to complete its review. These questions were provided in draft form and discussed with Mr. Gary Kilby of your staff on June 26, 2007. The draft questions were sent to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow FPLE to determine and agree upon a schedule to respond to the RAI. Subsequent to this discussion, some of the questions were modified or deleted.
In order to complete our review of this proposed change in a timely manner, a response to this request for additional information is required to be provided within 30 days. If you cannot respond within 30 days, please inform us in writing why you cannot respond and provide an alternate response date. This alternate response date must be no later than 60 days from the date of this letter.
G. St. Pierre Please note that if you do not respond to this letter within 30 days or provide an acceptable alternate date in writing, we may reject your request for approval under the provisions of Title 10 of the Code of Federal Regulations, Part 2, Section 2.108. If you have any questions, I can be reached at (301) 415-2481.
Sincerely,
/ra/
G. Edward Miller, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443
Enclosure:
RAI cc w/encl: See next page G. St. Pierre Please note that if you do not respond to this letter within 30 days or provide an acceptable alternate date in writing, we may reject your request for approval under the provisions of Title 10 of the Code of Federal Regulations, Part 2, Section 2.108. If you have any questions, I can be reached at (301) 415-2481.
Sincerely,
/ra/
G. Edward Miller, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443
Enclosure:
RAI cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrDorlDpr LPLI-2 R/F RidsNrrDorlLpl1-2(HChernoff)
RidsNrrPMGMiller RidsNrrLAABaxter RidsAcrsAcnwMailCenter RidsRgn1MailCenter(GMatakas)
DJohnson, NSIR RidsOgcRp Accession Number: ML071910442 *Via E-mail OFFICE LPLI-2/PM LPLI-2/LA DRA/AFPB/BC LPLI-2/BC NAME GEMiller ABaxter (MOBrien for)
MNorris for EWeiss*
HChernoff DATE 7/19/07 7/19/07 6/28/07 7/19/07 OFFICIAL RECORD COPY
Seabrook Station, Unit No. 1 cc:
Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Peter Brann Assistant Attorney General State House, Station #6 Augusta, ME 04333 Resident Inspector U.S. Nuclear Regulatory Commission Seabrook Nuclear Power Station P.O. Box 1149 Seabrook, NH 03874 Town of Exeter 10 Front Street Exeter, NH 03823 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Attorney General One Ashburton Place, 20th Floor Boston, MA 02108 Board of Selectmen Town of Amesbury Town Hall Amesbury, MA 01913 Mr. Robert Poole Federal Emergency Management Agency Region I 99 High Street, 6th Floor Boston, MA 02110 Mr. Tom Crimmins Polestar Applied Technology One First Street, Suite 4 Los Altos, CA 94019 John Giarrusso Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 Ms. Kelly Ayotte, Attorney General Mr. Orvil Fitch, Deputy Attorney General 33 Capitol Street Concord, NH 03301 Mr. Christopher M. Pope, Director Homeland Security & Emergency Mgmt.
New Hampshire Department of Safety Bureau of Emergency Management 33 Hazen Drive Concord, NH 03301 Mr. M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 James M. Peschel Regulatory Programs Manager FPL Energy Seabrook, LLC PO Box 300 Seabrook, NH 03874 Ms. Marjan Mashhadi Senior Attorney Florida Power & Light Company 801 Pennsylvania Ave., NW Suite 220 Washington, DC 20004
Seabrook Station, Unit No. 1 cc:
Mr. Mark E. Warner Vice President, Nuclear Operations Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420
REQUEST FOR ADDITIONAL INFORMATION CONVERSION TO NEI 99-01 EMERGENCY ACTION LEVELS (EALs)
FPL ENERGY SEABROOK, LCC SEABROOK STATION, UNIT NO. 1 DOCKET NO. 50-443 By letter dated December 29, 2006, FPL Energy Seabrook, LLC submitted a request for Nuclear Regulatory Commission (NRC) review and approval to implement the Emergency Action Levels contained in the Nuclear Energy Institute document, NEI 99-01, Methodology for Development of Emergency Action Levels Scheme, for the Seabrook Station, Unit No. 1.
Following discussions during the June 26, 2007, conference call, the NRC staff agreed that a response to questions 12 and 13-2 were not necessary for the NRC staffs decision. The NRC staff finds that the following information is required to complete its review:
RAI #
EAL Question 1
Definitions The definition for SABOTAGE is not as defined in NEI 99-01 R4.
Justify the inconsistency or use the NEI 99-01 R4 definition.
2 AU1
- 1. EAL 1a and 1b both have a 60-min component. Can this be implied to mean 120 minutes? Is the 1b 60-minute component required?
Explain.
- 2. Explain why the Offsite Dose Calculation Manual (ODCM) values are not included in EAL 2.
- 3. Third paragraph of Bases: How will you make sure that this EAL is declared if release start time is unknown or when it is determined that the release will exceed 60-min?
3 AU2 Explain why the actual indicators are not included in EAL 1a or include the indicators.
4 AA1
- 1. EAL 1a and 1b both have a 15-min component. Can this be implied to mean 30 minutes? Is the 1b 15-minute component required?
Explain.
- 3. Third paragraph of Bases: How will you make sure that this EAL is declared if release start time is unknown or when it is determined that the release will exceed 60-min?
5 AA3 EAL 2: The use of the term UNPLANNED appears to be inappropriate as defined in the 1st paragraph of the Bases. Correct discrepancy or justify.
6 CU1 Please explain what instrumentation you have available in these operating modes to make this determination. Refer to the approved EAL FAQ for this EAL.
RAI #
EAL Question 7
CU3/CA3 SU1/SA5 SS1/SG1
- 1. Is the use of Supplemental Emergency Power System controlled in your Tech Specs?
- 2. Explain why proposed NEI 99-01 R5 wording is not used here.
8 CA4 EAL 4: Is 10 psig within the calibrated range of the instrumentation used for this? What is the scale of the instrumentation?
9 CS2 EAL 2: Does the use of the term COMBINATION imply that you need more than one of these indicators to make the declaration? Justify or correct.
10 CG1
- 1. EAL 2: Does the use of the term COMBINATION imply that you need more than one of these indicators to make the declaration?
Justify or correct.
- 2. EAL 3: Does the 52 psig value take into account freeze seals and nozzle dams? Explain why proposed NEI 99-01 R5 wording is not used here.
11 E-HU1 Please explain why you are seeking approval for an EAL that is usually based upon your safety analysis report (SAR) when youve been approved for an Independent Spent Fuel Storage Installation? It does not appear that you have an approved SAR yet. Please explain.
12 FB Matrix Deleted per Conference Call on June 26, 2007 13 HU1
- 1. EAL 1: How is an earthquake recognized? Explain why the logic for EAL 1.b.1 is not OR with 1.b.2? Explain why proposed NEI 99-01 R5 wording is not used here.
- 2. Deleted per Conference Call on June 26, 2007
14 HU2 Explain how the requirements of paragraph 2 of the Bases are reconciled with the wording of the EAL. Specifically, does ANY fire within the protected area, not extinguished within 15-min, cause a declaration?
15 HU3 Explain in more detail why EAL 1.b was included alternately, the EAL may be removed.
16 HA1
- 1. Explain, if 1a and 1b are met, what value 1c has on the EAL.
17 HA4 Is Security Shift Supervision trained to recognize Radiological Sabotage? Explain why Bulletin 2005-02 was not followed.
18 HS4 It appears that there is a misspelling of the word HOSTILE.
19 SU5 Explain how you will know that unidentified leakage is from reactor coolant system?
RAI #
EAL Question 20 SU6/CU6 What telephones are you referring to (PABX, cell, satellite, etc.)? Can the nuclear alert system contact the NRC? Why are you limiting yourself to the emergency notification system line?
21 SA2/SS2/SG2 Explain why proposed NEI 99-01 R5 wording is not used here.
22 SS6 Explain why proposed NEI 99-01 R5 wording is not used here.
23 N/A Provide, as an attachment to your RAI responses, a complete and clean EAL Bases Document.