ML073110407
| ML073110407 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/17/2007 |
| From: | Florida Power & Light Energy Seabrook |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| SBK-L-06227 | |
| Download: ML073110407 (5) | |
Text
SUMMARY
EXPLANATION This submittal provides the necessary justification for changing the basis of the FPLE Seabrook Emergency Action Level (EAL) scheme from NUREG-0654 to NEI 99-01, Revision 4. It also demonstrates compliance with 10 CFR 50 Appendix E, and related guidance promulgated in Regulatory Issue Summary (RIS) 2003-18 (including Supplements 1 and 2).Submittal Package Contents This submittal package includes the transmittal letter and six enclosures.
- Enclosure 1 -Summary Explanation 0 Enclosure 2 -Comparison Matrix of NEI 99-01, Rev. 4, Generic Guidance To Proposed Seabrook Station Emergency Classification System* Enclosure 3 -Emergency Action Level Design Basis Document for Seabrook Station" Enclosure 4 -A draft revision of the Seabrook Station Radiological Emergency Plan to be implemented after receipt of change approval from the NRC" Enclosure 5 -State Government Official Agreement Documentation" Enclosure 6 -Background/technical information related to the development of the station-specific Initiating Conditions and EALs Current and Proposed EAL Scheme Bases FPLE Seabrook currently uses an emergency classification scheme based on NUREG-0654. FPLE Seabrook requests approval to change the scheme basis to that described in NEI 99-01, Revision 4, "Methodology for Development of Emergency Action Levels," January 2003, as endorsed by the Nuclear Regulatory Commission (NRC) in Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 4, July 2003. FPLE Seabrook further requests that the proposed changes receive NRC approval by December 31, 2007.Comparison of Scheme Basis to Proposed ICs and EALs The Initiating Conditions (ICs) and EALs that comprise the proposed scheme are presented in Enclosure
- 2. This matrix provides a cross-reference between each generic IC and EAL contained in NEI 99-01 and the proposed Seabrook Station-specific IC and EAL.Differences and Deviations are identified in accordance with the guidance discussed in RIS 2003-18 (and Supplements).
The basis for each Difference or Deviation is also included.The matrix follows the presentation order of NEI 99-01, Rev. 4 -Abnormal Rad Levels/Radiological Effluent, Cold Shutdown/Refueling System Malfunction, Events Related to Independent Spent Fuel Storage Installation (ISFSI), Fission Product Barrier Degradation, Hazards and Other Conditions Affecting Plant Safety, and System Malfunction.
The Defueled Station section is not used since Seabrook Station is an operating unit.Differences and Deviations Page 1 10/17/07
SUMMARY
EXPLANATION As discussed in Regulatory Issue Summary (RIS) 2003-18, Supplement 1, dated July 13, 2004, differences and deviations are defined as follows:* A difference is an EAL change where the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL. Examples of differences include the use of site-specific terminology or administrative re-formatting of site-specific EALs.* A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.).Enclosure 2 identifies each Difference and Deviation.
A summary description of these deviations and differences is presented below.IC Summary Description of Deviation CU5 IC not applicable in Mode 6 and EAL #1 not used. Seabrook Station has no Technical Specification Limiting Condition of Operation for RCS activity in Mode 6. In Mode 5, the station has no radiation monitor capable of directly determining if coolant activity exceeds Technical Specification allowable limits.E-HU2 IC and EAL not used. This IC and EAL were superceded by information promulgated in NRC Bulletin 2005-02. Attachment 2 of BL 2005-02 directed that E-HU2 be deleted because it is replaced by I either HA8 or HS4.HA4 EAL #1 not used. Generic EAL #1 was originally included in NEI 99-01, Rev. 4, when issued. This EAL was subsequently superceded.by information contained in NRC Bulletin 2005-02. BL 2005-02 stated, "Delete existing EALS as follows: 1. HA4 EAL1 (INTRUSION into the PROTECTED AREA by a HOSTILE FORCE) because it is replaced by the new HOSTILE ACTION EAL HA8." HA7 IC and EAL added. Initiating Condition HA7 was not included in NEI 99-01, Rev. 4, when originally issued. This IC and the associated EAL were subsequently incorporated into the NEI 99-01 scheme by NRC Bulletin 2005-02.HA8 IC and EAL added. Initiating Condition HA8 was not included in NEI 99-01, Rev. 4, when originally issued. This IC and the associated EAL were subsequently incorporated into the NEI 99-01 1 scheme by NRC Bulletin 2005-02.Page 2 10/17/07
SUMMARY
EXPLANATION IC Summary Description of Deviation HS1 IC and EAL not used. NRC Bulletin 2005-02 directed deletion of HS 1 EAL 1 (INTRUSION into the plant VITAL AREA by a HOSTILE FORCE) because it is replaced by the new HOSTILE ACTION EAL HS4. The events covered by EAL 2 are subsumed within IC HS4. With the inclusion of IC HS4, IC HS1 is not required.HS4 IC and EAL added. Initiating Condition HS4 was not included in NEI 99-01, Rev. 4, when originally issued. This IC and the associated EAL were subsequently incorporated into the NEI 99-01 scheme by NRC Bulletin 2005-02.SS4 IC and EAL not used. This IC and EAL are redundant with an IC and EALs contained in the Fission Product Barrier Degradation Matrix.Differences impacting 3 or more ICs, as identified in Enclosure 2, include the following:
IC Summary Description of Difference Various Pulled basis information into an IC or EAL. This was done in cases where knowledge and use of the basis information was essential to making the correct emergency classification.
Various Used mathematical symbols instead of text for value comparisons, e.g., replaced "greater than" with">".AU1, AA1, Seabrook Station does not have telemetered perimeter monitors.AS1, AG1 The generic EALs based on this capability were not used.CU2, CAI, Changed "unexplained sump and tank level increase" to CA2, CS1, "unexplained increases in sump and/or tank levels" since these CG1 levels may respond independently.
CU3, CA3, Use of "buses", not "transformers", for loss of AC power events.SU1, SS1, Utilized bus indications to focus the classification on the loss of an SG1 AC emergency bus rather than the status of one or more transformers that may or may not be capable of powering the bus(es).CU2, CU4, Substituted term "reactor vessel" for "RPV" to be consistent with CAl, CA2, station procedures.
CA4, CS 1, CS2, CG1 CA4, CS 1, Substituted term "Containment integrity is [is not] established as CS2, CG1 tracked by Procedure OS1056.03, Containment Penetrations" for"CONTAINMENT CLOSURE is [is not] established".
Procedure OS 1056.03 is used to track containment penetration status during shutdown conditions.
SA2, SS2, Substituted term "ATWS" for the text description of the IC event SG2 to be consistent with station procedures.
Included site-specific EAL criteria for determining if a manual reactor trip was successful (i.e., results in neutron flux < 5%).Page 3 10/17/07
SUMMARY
EXPLANATION These differences, as well as the others identified in Enclosure 2, do not alter the meaning or intent of the ICs or EALs.Incorporation of EALFAQs Where appropriate, information from recent Emergency Action Level Frequently Asked Questions (EALFAQs) have been incorporated into Enclosure 2 and Enclosure 3.Related Documents Enclosure 3 is the site-specific technical basis document for the proposed scheme. This document was derived from the basis information contained in NEI 99-01, Revision 4.The proposed change to the Seabrook Station Radiological Emergency Plan that will implement the new emergency classification scheme is presented in Enclosure 4.Enclosure 6 contains background/technical information related to the development of the station-specific Initiating Conditions and EALs such as referenced station procedures, drawings, calculations, etc.Operational Modes and Applicability Mode applicability of the proposed ICs and EALs is consistent with the NEI 99-01, Revision 4 basis scheme with the one exception noted above (i.e., CU5). The Operating Modes for Seabrook Station, as defined in the Technical Specifications, are listed below.REACTIVITY
% RATED AVERAGE MODE CONDITION, THERMAL COOLANT keff POWER* TEMPERATURE
- 1. POWER > 0.99 >5% > 350 0 F OPERATION 2. STARTUP > 0.99 <5% > 3500 F 3. HOT STANDBY < 0.99 0% > 3500 F 4. HOT SHUTDOWN < 0.99 0% 3500 F > TAVG> 2000 F 5. COLD SHUTDOWN < 0.99 0% < 2000 F 6. REFUELING**
<.95 0% < 1400 F* Excluding decay heat.** Fuel in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed.In addition to the Technical Specification operational modes, NEI 99-01, Revision 4, also defines the following additional mode: Page 4 10/17/07
SUMMARY
EXPLANATION Defueled:
All reactor fuel removed from reactor pressure vessel.(Full core off load during refueling or extended outage)Station procedures recognize, and are consistent with, this Mode definition.
Agreement by State Government Officials The Seabrook Station Emergency Planning Zone (EPZ) includes two States, New Hampshire and Massachusetts.
Meetings with representatives of emergency management and public health agencies from both States were conducted to review the proposed classification scheme in detail. This review included the identification of differences between the current NUREG-0654 scheme and the proposed NEI 99-01 scheme, and the resulting changes in classifications.
Agreement with the proposed scheme change has been obtained from both EPZ States.Documentation of these agreements is contained in the following letters.1) Letter from Kathryn Doutt, Assistant Director, New Hampshire Homeland Security and Emergency Management, to Susan Perkins-Grew, Emergency Preparedness Manager, FPLE Seabrook Station, dated October 23, 2006.2) Letter from Cristine McCombs, Director, Massachusetts Emergency Management Agency, to Susan Perkins-Grew, Emergency Preparedness Manager, FPLE Seabrook Station, dated October 27, 2006.The above letters are presented in Enclosure 5.Under protocols established with New Hampshire and Massachusetts offsite response organizations, officials from the State emergency management agencies provide review of proposed changes to the EALs used by Seabrook Station. Local emergency management officials are advised of any EAL changes actually implemented.
In the case of this EAL scheme conversion, Seabrook Station has committed to provide a review of the new classification scheme to local emergency management officials following NRC approval and prior to implementation.
Implementation Description FPLE Seabrook plans to implement the proposed emergency classification scheme in the third quarter of 20081. When implemented, the change to the Seabrook Station Radiological Emergency Plan presented in Enclosure 4 will become effective.
The ICs and EALs presented in Enclosure 2 will be incorporated into Procedure ER 1.1, Classification of Emergencies.
The Emergency Action Level Design Basis Document (Enclosure
- 3) will be maintained as a training and background reference resource.
Any changes to the approved ICs and EALs will be made in accordance with 10 CFR 50.54(q).This plan is contingent on several factors including the anticipated time required for NRC review and approval, Refueling Outage 12 to be conducted in the spring of 2008, and the 2008 Exercise in the fall.Page 5 10/17/07